Justia Criminal Law Opinion Summaries

Defendant pleaded guilty to seven counts of possession of pornographic work involving minors for downloading and saving seven pornographic images of minors engaged in sexual conduct on seven different days. Before sentencing, Defendant filed a motion arguing (1) he could only be convicted and sentenced for one count of possession for possessing the computer, and (2) his offenses were part of a single behavioral incident. The district court denied the motion. The Supreme Court affirmed, holding that the district court did not err in sentencing Defendant on each of the separate possession convictions, as Defendant’s sentences were completed at substantially different times, and his conduct was not motivated by an effort to obtain a single criminal objective. View "State v. Bakken" on Justia Law

Appellant entered a Norgaard plea to third-degree criminal sexual conduct. The district court imposed a downward durational departure from the presumptive sentence, concluding in part that Appellant’s remorse provided substantial reasons to depart from the presumptive sentence length. The court of appeals reversed the downward durational departure because Appellant’s remorse did not make his conduct "less serious than the typical offense.” The court further found that even if Appellant’s remorse were a mitigating factor, Appellant was not entitled to a downward departure based on one mitigating factor alone. The Supreme Court affirmed, holding (1) a single mitigating factor may provide a substantial reason to impose a downward durational sentencing departure; but (2) a downward durational departure was not warranted in this case because Appellant’s expressions of remorse did not diminish the seriousness of his offense. View "State v. Solberg" on Justia Law

After a jury trial, Appellant was found guilty of first-degree murder of a peace officer and nine other felonies. The Supreme Court affirmed Appellant’s first-degree murder conviction and all but one of his other felony convictions. Thereafter, Appellant filed a petition for postconviction relief, asserting, inter alia, that he did not actually cause the death of the officer. The postconviction court denied Appellant’s petition without an evidentiary hearing. The Supreme Court affirmed, holding that the postconviction court did not abuse its discretion when it denied Appellant’s petition without holding an evidentiary hearing. View "Fairbanks v. State" on Justia Law

In 2008, Appellant was convicted of three counts of first-degree murder and four counts of second-degree murder. Appellant was sentenced to life imprisonment without the possibility of release. The Supreme Court affirmed on appeal. In 2012, Appellant filed a petition for postconviction relief, alleging numerous trial errors as well as ineffective assistance of counsel. The postconviction court summarily denied most of Appellant’s claims on the ground that they were procedurally barred. Following an evidentiary hearing, the court denied Appellant’s remaining ineffective assistance of counsel claims. The Supreme Court affirmed, holding (1) most of Defendant’s claims were procedurally barred, and therefore, the postconviction court did not abuse its discretion by denying them without granting an evidentiary hearing; and (2) the district court did not err when it denied several of Appellant’s ineffective assistance of counsel claims after an evidentiary hearing. View "Swaney v. State" on Justia Law

Appellant was convicted of attempted third-degree criminal sexual conduct. The district court sentenced Appellant to eighteen months in prison and imposed a ten-year conditional release term under Minn. Stat. 609.3455(6). The court of appeals affirmed the imposition of the ten-year conditional release term. The Supreme Court reversed, holding that section 609.3455(6) does not authorize a ten-year conditional release term for the crime of attempted third-degree criminal sexual conduct, and therefore, Appellant’s ten-year conditional release term was unauthorized by law and must be vacated. Remanded with instructions to vacate Appellant’s ten-year conditional release term. View "State v. Noggle" on Justia Law

After a jury trial, Appellant was convicted of first-degree premeditated murder and sentenced to life imprisonment without the possibility of release. Appellant appealed, alleging several claims of error. The Supreme Court affirmed, holding (1) the district court did not deprive Appellant of his Sixth Amendment right to counsel when it denied his request for advisory counsel to assume full representation of his case at trial; (2) the district court did not commit errors that, either individually or taken together, denied Appellant a fair trial; and (3) Appellant was not prejudiced by any error in the district court’s refusal to instruct the jury on the lesser-included offense of first-degree manslaughter. View "State v. Chavez-Nelson" on Justia Law

Appellant was charged with second-degree intentional murder. Appellant offered to plead guilty to that charge, but the State rejected the offer. A grand jury subsequently indicted Appellant for first-degree premeditated murder. Appellant was convicted and sentenced to life imprisonment. Appellant appealed and sought postconviction relief, claiming ineffective assistance of counsel and prosecutorial misconduct. The postconviction court denied relief. The Supreme Court affirmed, holding (1) the district court did not err in denying Appellant’s motion to dismiss the first-degree murder indictment as untimely; (2) the postconviction court did not err in dismissing Appellant’s ineffective assistance claim without an evidentiary hearing; and (3) the postconviction court’s findings that there was no prosecutorial misconduct were not clearly erroneous. View "State v. Vang" on Justia Law

After a jury trial, Appellant was convicted of six counts of soliciting and promoting prostitution and conspiracy to commit sex trafficking. The district court sentenced Appellant to an aggregate sentence of 432 months’ imprisonment. The court of appeals affirmed. The Supreme Court affirmed the convictions, holding (1) the statute that criminalizes the promotion and solicitation of prostitution is not substantially overbroad under the First Amendment; (2) the district court gave plainly erroneous accomplice-liability jury instructions, but the instructions did not affect Appellant’s substantial rights; and (3) the evidence presented at trial was sufficient to support Appellant’s convictions. View "State v. Washington-Davis" on Justia Law

Darek Jon Nelson pleaded guilty to first-degree premeditated murder and was sentenced to life in prison without the possibility of release. The postconviction court subsequently denied Nelson's petition for postconviction relief asking to withdraw his guilty plea. In this case, the record clearly shows that Nelson understood the charges against him, understood the rights he was waiving, and understood the consequences of his plea. Therefore, the court affirmed the judgment, concluding that Nelson did not meet his burden to show that his guilty plea was not entered intelligently, accurately, or voluntarily. View "Nelson v. State of Minnesota" on Justia Law

After a jury trial, Defendant was convicted of two counts of first-degree premeditated murder, first-degree arson of a dwelling and theft of a motor vehicle. The Supreme Court affirmed on appeal. Thereafter, Defendant filed a petition for postconviction relief, alleging claims of trial error, ineffective assistance of trial counsel, and ineffective assistance of appellate counsel. The postconviction court denied the petition without granting an evidentiary hearing, concluding that Defendant’s claims were either procedurally barred or meritless. The Supreme Court affirmed, holding (1) Defendant’s claims of trial error were procedurally barred; (2) Defendant’s ineffective assistance of trial counsel claims were either procedurally barred or did not otherwise entitle him to an evidentiary hearing; and (3) Defendant did not receive ineffective assistance of appellate counsel. View "Zornes v. State" on Justia Law