Justia Criminal Law Opinion Summaries

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

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