Justia Criminal Law Opinion Summaries

Appellant was convicted of first-degree murder for the benefit of a gang on an accomplice-liability theory. The Supreme Court affirmed. After unsuccessfully filing two postconviction petitions, Appellant filed a third postconviction petition in which he alleged that three witnesses presented false testimony at his trial. Following an evidentiary hearing, the postconviction court denied Appellant’s third postconviction petition. The Supreme Court affirmed, holding (1) the postconviction court did not err when it rejected Appellant’s claim that the prosecutor intimidated a recanting witness when it apprised the witness of his Fifth Amendment rights; and (2) the postconviction court did not err when it struck the testimony the witness gave before invoking his Fifth Amendment privilege. View "Caldwell v. State" on Justia Law

After a jury trial, Defendant was found guilty of first-degree premeditated murder, second-degree intentional murder, and second-degree felony murder. The district court sentenced Defendant, who was eighteen years old at the time he committed the offense, to life in prison without the possibility of release for the first-degree premeditated murder conviction. The Supreme Court affirmed as modified, holding (1) the district court did not err when it denied Defendant’s motion to suppress his confessions because the confessions were voluntary; (2) Defendant forfeited his claim that his mandatory sentence of life imprisonment without the possibility of release violates the Eighth Amendment prohibition on cruel and unusual punishment because he was psychologically and socially a juvenile when he committed the crime; and (3) because the order attached to the Warrant of Commitment incorrectly listed convictions for the two lesser-included offenses, those two convictions are vacated. View "State v. Nelson" on Justia Law

After Defendant was arrested on suspicion of driving while impaired, officers requested that he submit to a warrantless blood or urine test. Defendant agreed to provide a urine sample, but the officer believed that Defendant tampered with the sample and therefore treated his conduct as a refusal. Defendant refused to submit to a blood test. The State charged Defendant with first-degree refusal. Defendant pleaded guilty. Defendant later argued that his guilty plea was not knowing, voluntary, or intelligent because the test refusal statute was unconstitutional as applied. The postconviction court denied relief. The court of appeals affirmed. After deciding State v. Bernard, the Supreme Court reversed the court of appeals’ decision that the test refusal statute was constitutional and remanded for reconsideration. On remand, the court of appeals reversed Defendant’s conviction. The Supreme Court affirmed, holding that Defendant cannot be prosecuted for refusing to submit to an unconstitutional warrantless blood test, and the test refusal statute is unconstitutional as applied. View "State v. Trahan" on Justia Law

After Defendant was arrested on suspicion of driving while impaired, officers asked him to submit to a warrantless blood or urine test. Defendant refused both tests. The State charged Defendant with second-degree test refusal, among other counts. Defendant moved to dismiss the test refusal charge, arguing that the statute was unconstitutional. The district court denied the motion and found Defendant guilty of test refusal. The court of appeals reversed, concluding that charging a defendant with test refusal violates a fundamental right. The Supreme Court affirmed, holding that the test refusal statute is unconstitutional as applied to Defendant. View "State v. Thompson" on Justia Law

After a jury trial, Defendant was convicted of one count of first-degree premeditated murder and two counts of attempted first-degree premeditated murder. The Supreme Court affirmed the convictions on appeal. Defendant later filed a petition for postconviction relief, arguing that appellate counsel was ineffective for failing to raise several issues on appeal. The postconviction court denied the petition without holding an evidentiary hearing. The Supreme Court affirmed, holding that Defendant could not show prejudice from his appellate counsel’s alleged errors, and therefore, the postconviction court did not abuse its discretion by denying Defendant’s postconviction motion without holding an evidentiary hearing. View "Morrow v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree premeditated murder and other crimes. Defendant was sentenced to life imprisonment without the possibility of release. Defendant appealed, asserting a number of errors. The Supreme Court affirmed, holding (1) there was sufficient evidence to support Defendant’s convictions; (2) the district court did not commit reversible error when it disallowed certain defense evidence offered at trial; (3) Defendant was not denied the effective assistance of trial counsel; (4) Defendant was not entitled to a sentencing hearing under Miller v. Alabama; and (5) Defendant’s claims offered in a pro se supplemental brief lacked merit. View "State v. Robertson" on Justia Law

After a jury trial, Appellant was found guilty of one count of first-degree murder of a peace officer, three counts of attempted first-degree murder of a peace officer, and one count of unauthorized possession of a firearm. The Supreme Court affirmed, holding (1) the district court did not violate Defendant’s right under the Minnesota Constitution to be tried by a jury of the county or district in which the alleged offense occurred; and (2) the district court did not commit prejudicial error by refusing to sever the first-degree murder charge from the other charges in Appellant’s case for the purpose of trial. View "State v. Fitch" on Justia Law

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