Justia Criminal Law Opinion Summaries

Defendant was arrested and charged with drug-related crimes. The district court ordered Defendant’s pretrial release. The district court later found probable cause that Defendant had violated the conditions of her release and issued a warrant for her arrest. Officers then went to the residence of Defendant’s boyfriend. One officer opened an unlocked door, went inside, and arrested Defendant. While arresting her, the officer saw marijuana and a bong in plain view. Law enforcement then obtained a search warrant for the apartment of Defendant’s boyfriend. The state subsequently charged Defendant with two counts of fifth-degree possession of a controlled substance and possession of drug paraphernalia. The district court suppressed all fruits of Defendant’s arrest and dismissed the charges, concluding that the arrest was illegal because the warrant for Defendant's arrest did not authorize police to enter her boyfriend’s apartment. The court of appeals reversed. The Supreme Court affirmed, holding that neither the Fourth Amendment of the U.S. Constitution nor Article I, Section 10 of the Minnesota Constitution requires police to obtain a search warrant before entering a home to arrest a guest who is the subject of a lawfully issued arrest warrant. View "State v. deLottinville" on Justia Law

After the Supreme Court overturned Petitioner’s first conviction on direct appeal, Petitioner was tried a second time and convicted of first-degree murder while committing or attempting to commit a kidnapping. Petitioner was sentenced to life in prison without the possibility of release. The Supreme Court affirmed. This appeal concerned Petitioner’s third petition for postconviction relief in which Petitioner raised a variety of claims. The postconviction court summarily denied the claims as either meritless or untimely filed. The Supreme Court affirmed, holding that the postconviction court did not abuse its discretion in summarily denying the petition, as one of Petitioner’s claims was meritless and the remaining claims were untimely filed. View "Hannon v. State" on Justia Law

Defendant was convicted of first-degree premeditated murder and sentenced to life in prison without the possibility of release. The court concluded that the district court did not commit plain error in admitting evidence of defendant's post-arrest, pre-Miranda silence during the State's case-in-chief; any error by the district court in permitting the State to discuss defendant's post-arrest, pre-Miranda silence in closing argument was harmless; and the district court did not abuse its discretion in denying defendant's request to give a jury instruction on defense of dwelling. Accordingly, the court affirmed the judgment. View "State of Minnesota v. Lilienthal" on Justia Law

Defendant was convicted of a petty misdemeanor for violating Lester Prairie Municipal Code section 5.5.1.2, which prohibits certain blight conditions on residents’ property, including the open storage of unregistered or inoperative motor vehicles. The court of appeals reversed, concluding that the ordinance was ambiguous and resolving the ambiguity in favor of Defendant. The Supreme Court reversed, holding (1) the unambiguous language of the ordinance prohibits a person from keeping a junked or abandoned vehicle or other scrap metal on her property for longer than thirty days without a special use permit; and (2) there was sufficient evidence to prove that Defendant violated the ordinance by keeping an abandoned vehicle on her property for longer than thirty days without a special use permit. View "State v. Vasko" on Justia Law

John David Emerson was arrested and charged with second-degree assault with a dangerous weapon. Upon Emerson’s motion, the district court issued an order restraining the Dakota County Sheriff from collecting Emerson’s DNA for law enforcement identification purposes. The Sheriff filed a petition for a writ of prohibition asking the court of appeals to prohibit the district court from enforcing its order against the Sheriff, arguing that the district court lacked subject matter jurisdiction to hear and decide Emerson’s motion. The court of appeals denied the motion. The Supreme Court reversed, holding (1) the district court had subject matter jurisdiction but exceeded its lawful authority when it used the wrong procedure to address Emerson’s constitutional challenge the DNA-collection statute; and (2) the Sheriff met all three elements for a writ of prohibition. View "In re Leslie, Dakota County Sheriff" on Justia Law

After a jury trial, Appellant was found guilty of first-degree murder, first-degree attempted murder, and other crimes. The district court sentenced Appellant to consecutive terms of life imprisonment without the possibility of release for the murder and attempted murder convictions. The Supreme Court affirmed the convictions, holding that the district court did not err when it (1) excluded evidence that Defendant claimed was relevant to an element of his self-defense claim; (2) denied Defendant’s request for a third-degree murder instruction; and (3) denied Defendant’s pretrial motion to dismiss the first-degree murder charge. View "State v. Zumberge" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder while committing a felony involving the unlawful sale of a controlled substance. The district court sentenced Appellant to life imprisonment with the possibility of release after serving a minimum of thirty years in prison. The Supreme Court affirmed Appellant’s conviction on direct appeal. This appeal concerned Appellant’s second petition for postconviction relief, in which he argued that there was insufficient evidence to support his conviction. The postconviction court summarily denied Appellant’s petition. The Supreme Court affirmed, holding that the postconviction court did not abuse its discretion in denying Appellant’s postconviction petition without holding an evidentiary hearing. View "Gail v. State" on Justia Law

In 2008, Respondent pleaded guilty to failing to register as a predatory offender. The district court sentenced Respondent to one year and one day in prison. In 2009, the district court sua sponte modified Respondent’s sentence to include a ten-year conditional release term. More than four years later, Respondent brought a motion under Minn. R. Crim. P. 27.03(9) to correct his sentence, arguing that the conditional release term violated Blakely v. Washington. The district court treated Respondent’s motion as a petition for postconviction relief and determined that the expiration of the two-year limitations period in the postconviction statute required the dismissal of Respondent’s claim. The court of appeals reversed, concluding that Respondent’s challenge to his conditional release term could be brought at any time because it fell within the scope of Rule 27.03(9) and that the imposition of the conditional release term violated Respondent’s Sixth Amendment right to a jury trial. The Supreme Court affirmed, holding (1) Respondent’s challenge was properly brought under Rule 27.03(9); and (2) applying the two-year limitations period in the postconviction statute to a motion brought under Rule 27.03(9) violates the separation of powers. View "Reynolds v. State" on Justia Law

Defendant was convicted of first-degree assault for pushing D.E. twice in the chest, causing D.E. to stumble into a nearby bonfire and sustain burn injuries. The court of appeals affirmed. Defendant appealed, arguing that the evidence was insufficient to sustain her conviction because she did not intentionally harm D.E. and her actions did not directly cause D.E.’s injuries. The Supreme Court affirmed, holding that the evidence was sufficient to sustain Defendant’s conviction for first-degree assault because (1) Defendant’s application of force to D.E. was “intentional,” (2) Defendant’s conduct constituted a battery and was therefore an “infliction” of harm, and (3) Defendant’s conduct was the direct cause of D.E.’s injuries. View "State v. Dorn" on Justia Law

Defendant pled guilty to felony domestic assault in district court. Following sentencing, Ramsey County Community Corrections notified the district court that Defendant was required to register as a predatory offender due to his conviction. Defendant filed a motion to withdraw his guilty plea on the ground that he had not been aware that his conviction would trigger the requirement to register as a predatory offender. The district court denied the request. The court of appeals affirmed. The Supreme Court affirmed, holding that a defense attorney’s failure to advise a defendant about predatory offender registration requirements before the defendant enters a plea of guilty does not violate a defendant’s right to effective assistance of counsel, and therefore, Defendant was not entitled to withdraw his guilty plea. View "Taylor v. State" on Justia Law