Justia Criminal Law Opinion Summaries

After a jury trial, Appellant was found guilty of first-degree premeditated murder, two counts of first-degree intentional felony murder, and first-degree aggravated robbery. Appellant was sentenced to life without the possibility release for the murder conviction. The Supreme Court affirmed, holding (1) the district court did not err in denying Appellant’s motion to suppress a confession he gave to police following his arrest, as the totality of the circumstances did not support Appellant’s argument that his confession to police was involuntary; and (2) the evidence was sufficient to support the jury’s verdict that Appellant committed premeditated murder. View "State v. Cox" on Justia Law

Appellant drove her car through a red light, causing a collision with another car. A police detective applied for and was issued a warrant to search a sample of Appellant’s blood for “evidence of criminal vehicular operation.” The issuing judge found that probable cause existed for the issuance of the search. After Appellant’s blood was drawn, a toxicology report indicated that Appellant's blood contained a metabolite of THC and Alprazolam at the time of the accident. The State charged Appellant with criminal vehicular operation. Appellant filed a motion to suppress, arguing that the warrant did not provide probable cause for the police to test her blood for controlled substances. The district court granted Appellant’s motion, concluding that the blood sample was lawfully obtained under the warrant but that the subsequent testing of the blood sample for the presence of drugs was unlawful. The court of appeals reversed. The Supreme Court affirmed, holding (1) the facts alleged in the warrant application and supporting affidavit supported testing Appellant’s blood for controlled substances; and (2) the search warrant satisfied the particularity requirement in the Fourth Amendment. View "State v. Fawcett" on Justia Law

Defendant was charged with several criminal counts. When the State’s only witness failed to appear in court, the State requested a continuance, but the district court denied the request. The State subsequently voluntarily dismissed the case and then refiled the criminal charges against Defendant. Defendant filed a motion to dismiss, arguing that the State’s approach would allow the State to circumvent the court’s denial of a continuance. The district court denied Defendant’s motion to dismiss. The court of appeals reversed, concluding that the State’s “dismiss-and-refile tactic” was an act of bad faith. The Supreme Court reversed, holding that the district court did not abuse its discretion when it denied Defendant’s motion to dismiss the refiled charges. View "State v. Olson" on Justia Law

After a jury trial, Appellant was found guilty of two counts of first-degree felony murder and two counts of attempted first-degree felony murder. Appellant was fifteen years old at the time of the murders. The district court imposed two mandatory sentences of life imprisonment with the possibility of release after thirty years for the murder convictions and ordered Defendant’s sentences to be served consecutively. The Supreme Court affirmed on direct appeal. Appellant later moved to correct his sentences, asserting that his sentences were void because the juvenile court failed to follow the proper adult-certification procedures before referring him to adult court. Construing Appellant’s motion to correct his sentence as a petition for postconviction relief, the postconviction court summarily denied relief, concluding that Appellant’s petition was procedurally barred under the Knaffla rule. The Supreme Court affirmed, holding that the postconviction court (1) did not err by construing Appellant’s motion to correct his sentence as a petition for postconviction relief; and (2) did not abuse its discretion by summarily dying relief because Appellant’s postconviction petition was procedurally barred. View "Ouk v. State" on Justia Law

Appellant pleaded guilty to possession of a firearm by an ineligible person and second-degree assault. The district court imposed an upward durational sentencing departure for the possession conviction on the grounds that Appellant fired the gun six times in a park filled with children, thereby putting a large number of individuals in real and significant danger of bodily harm. On appeal, Appellant contended that “the firing of the gun related only to the assault conviction and that the conduct underlying the assault conviction could not be used to support an upward departure for the possession conviction.” The Supreme Court affirmed, holding that the plain language of Minn. Stat. 244.10(5)(a)(b) authorized the upward departure, as the firing of the gun made Appellant’s illegal possession of the gun more egregious than the typical possession offense, even if the firing of the gun was part of the same course of conduct as the assault offense. View "State v. Fleming" on Justia Law

In 2006, Appellant was found guilty of murder. The Supreme Court affirmed on appeal. In 2013, Appellant filed a petition for postconviction relief, asserting that certain medical evidence, known to Appellant at the time of his direct appeal, contradicted the opinion testimony of the State’s medical expert at trial. The postconviction court denied the petition, concluding that the petition was not timely filed and was procedurally barred under the Knaffla rule. The Supreme Court affirmed, holding that the the postconviction court did not err in summarily dismissing Appellant’s petition because it was untimely under Minn. Stat. 590.01(4)(a). View "Jones v. State" on Justia Law

Appellant pleaded guilty to one count of failure to register as a predatory offender. Appellant later filed a petition for postconviction relief seeking to withdraw his guilty plea on the ground that it was inaccurate and lacked an adequate factual basis. The postconviction court denied the petition, concluding that it was untimely under Minn. Stat. 590.01(4)(c). The court of appeals affirmed. On appeal, Appellant argued that the postconviction court was required to consider his petition on the merits because the State forfeited its right to assert section 590.01(4)(c) as an affirmative defense. The Supreme Court reversed, holding (1) when the State fails to raise the time limits set forth in section 590.01(4)(a) and (c), the postconviction court has the discretion to consider the time limits on its own motion, but before ruling on the issue, the court must give notice to the parties and an opportunity to be heard; and (2) because the postconviction court in this case failed to give the parties notice that it intended to consider on its own motion the statute of limitation in section 590.01(4)(c), the case must be remanded to allow the parties the opportunity to be heard on the timeliness of Appellant’s petition. View "Weitzel v. State" on Justia Law

After a jury trial, Appellant was convicted of first-degree premeditated murder. Appellant was sentenced to life imprisonment without the possibility of release. The Supreme Court affirmed on direct appeal. After unsuccessfully seeking postconviction relief in three successive petitions, Appellant filed the present petition for postconviction relief, arguing again that his right to effective assistance of counsel was violated and that the Supreme Court applied the wrong precedent in assessing this claim during his direct appeal. The postconviction court denied the petition as both untimely and procedurally barred. The Supreme Court affirmed, holding that Appellant’s petition was untimely and therefore frivolous and was properly denied. View "Brocks v. State" on Justia Law

Appellant was charged with first-degree premeditated murder. On the date of the murder, Appellant was seventeen years old. The district court sentenced Appellant to life imprisonment without the possibility of release (LWOR). Appellant later filed a petition for postconviction relief claiming that he was entitled to a new trial because an eyewitness recanted his trial testimony and that his mandatory sentence of LWOR should be reversed based on Miller v. Alabama. The postconviction court denied Appellant’s petition after an evidentiary hearing. The Supreme Court (1) affirmed in part, holding that the postconviction court did not abuse its discretion by ruling that the eyewitness’s out-of-court statements were not admissible under Minn. R. Evid. 804(b)(3); but (2) vacated Appellant’s LWOR sentence because the mandatory statutory scheme under which his sentence was imposed was unconstitutional as applied according to Montgomery v. Louisiana. Remanded for resentencing. View "Jackson v. State" on Justia Law

After a jury trial, Appellant was found guilty of two first-degree murder offenses - premeditated murder and drive-by shooting - for the shooting death of one victim. The district court sentenced Appellant to life imprisonment without the possibility of release on the first-degree premeditated murder conviction. The Supreme Court affirmed. Appellant later filed a petition for postconviction relief, asserting that he received ineffective assistance of both trial and appellate counsel. The postconviction court denied relief without holding a hearing. The Supreme Court affirmed, holding that the postconviction court did not err in summarily denying relief. View "Griffin v. State" on Justia Law