Justia Criminal Law Opinion Summaries

The case involves Anthony James Trifiletti, who was convicted of second-degree unintentional felony murder. The conviction followed a second trial after the first ended in a mistrial due to a deadlocked jury. During the second trial, one of the State’s witnesses was exposed to COVID-19 and was deemed unavailable to testify in person. The district court allowed the transcript of her testimony from the first trial to be read into the record instead of live testimony. Trifiletti appealed, arguing that this violated his right to confrontation under the Sixth Amendment to the United States Constitution and Article I, Section 6, of the Minnesota Constitution.The Minnesota Supreme Court held that the district court erred in determining that the witness was unavailable under the Confrontation Clause. The court found that the State failed to establish that the witness would not have been available to testify in person at some reasonable point in time during the trial. The court also rejected the State's argument that Trifiletti invited the error by choosing to have the witness's prior testimony read aloud for the jury rather than having her testify via video. However, the court concluded that the error was harmless beyond a reasonable doubt, as the jury's determination that Trifiletti did not act in self-defense was surely unattributable to the witness's testimony. Therefore, the court reversed the decision of the court of appeals. View "State of Minnesota vs. Trifiletti" on Justia Law

The case revolves around the 1986 murder of Nancy Daugherty. The defendant, Michael Allan Carbo Jr., was charged with two counts of first-degree murder. The prosecution's case was based on DNA evidence collected from the crime scene and Carbo's garbage, which matched Carbo's DNA. Carbo sought to suppress this evidence, arguing that the collection and analysis of his DNA violated his Fourth Amendment rights. He also sought to introduce evidence suggesting that another individual, B.E., was the actual perpetrator.The district court denied Carbo's motion to suppress the DNA evidence, ruling that Carbo had abandoned his expectation of privacy by leaving his semen at the crime scene and his garbage in a communal bin. The court also denied Carbo's motion to introduce alternative-perpetrator evidence, concluding that the proffered evidence did not have an inherent tendency to connect B.E. to the crime.The Minnesota Supreme Court affirmed the lower court's decision regarding the DNA evidence. It held that Carbo had indeed abandoned his subjective expectation of privacy in the genetic information gathered from the crime scene and his garbage. However, the court reversed the lower court's decision on the alternative-perpetrator evidence. It found that the district court had abused its discretion by holding Carbo's evidentiary proffer to an unobtainable legal standard, thereby violating his constitutional right to present a complete defense. The court concluded that the error was not harmless and remanded the case for further proceedings. View "State of Minnesota vs. Carbo" on Justia Law

The case revolves around the appellant, Said Sharif Maye, who was convicted of second-degree unintentional murder for the death of Idris Yussuf in August 2020. Prior to the trial, the district court denied Maye's motion to exclude testimony that the State's main eyewitness received several threatening phone calls before the trial, instructing him not to testify. The State argued that the evidence was relevant to the witness's credibility, showing that he was willing to testify despite threats. The district court allowed the evidence, reasoning that it was probative of the witness's credibility and that the prejudicial effect of the evidence would be mitigated by the State's suggested clarifying questions.The court of appeals affirmed Maye's conviction, holding that the district court did not abuse its discretion in admitting evidence of the threatening phone calls. The court of appeals reasoned that the evidence was relevant to the witness's credibility, the State's use of the evidence was minimal, and the evidence was admitted with sufficient safeguards to protect against unfair prejudice. The court of appeals also held that even if the evidence was erroneously admitted, its admission was harmless.The Supreme Court of Minnesota held that the district court abused its discretion by admitting the threat evidence on direct examination. The court reasoned that the probative value of the evidence was minimal, and the risk of unfair prejudice to the defendant was substantial. However, the court affirmed the decision of the court of appeals, agreeing that the admission of the evidence was harmless. The court concluded that there was no reasonable possibility that the wrongfully admitted evidence significantly affected the verdict, given the strong evidence of Maye's guilt. View "State of Minnesota vs. Mcneilly" on Justia Law

The case revolves around the appellant, Said Sharif Maye, who was convicted of second-degree unintentional murder for the death of Idris Yussuf in August 2020. Before the trial, the district court denied Maye’s motion to exclude testimony that the State’s main eyewitness received several threatening phone calls before trial telling him not to testify. At trial, the State questioned the eyewitness about the threats at the end of direct examination. The court of appeals affirmed Maye’s conviction and held that the district court did not abuse its discretion in admitting evidence of the threatening phone calls.The Minnesota Supreme Court was tasked with determining whether the district court abused its discretion in admitting evidence on direct examination that a witness received threatening phone calls from an unknown caller and, if so, whether any such error was harmless. The court found that the district court did abuse its discretion by admitting the threat evidence on direct examination. However, the court affirmed the decision of the court of appeals because it agreed that the admission of the evidence was harmless. The court concluded that there was no reasonable possibility that the erroneously admitted threat evidence significantly affected the verdict. View "State of Minnesota vs. Maye" on Justia Law

The case involves Jerry Arnold Westrom, who was convicted of first-degree premeditated murder and second-degree intentional murder. The victim, Jeanie Childs, was found stabbed to death in her apartment in 1993. The case went cold until 2018 when police began working with the FBI to review Childs’ murder. They sent a DNA sample from the crime scene to DNA Solutions, Inc. to create a single nucleotide polymorphism (SNP) profile that could be compared with profiles on commercial genealogical databases to identify the source’s relatives. A potential match was located on MyHeritage that appeared to be a first cousin to the source of the crime scene DNA. Law enforcement then used the match to construct a family tree that identified Westrom as the likely source.The district court denied Westrom’s motion to suppress all evidence stemming from the police’s comparison of the SNP profile created from DNA gathered from the crime scene with other profiles on commercial genealogical databases. His motion also contested the admissibility of evidence obtained through the STR analysis of DNA taken from his discarded napkin. The district court concluded that no search had occurred because Westrom held no expectation of privacy in the information contained within his DNA when police only used his DNA for the purpose of identification.The Minnesota Supreme Court affirmed Westrom’s conviction of first-degree premeditated murder. The court found that the district court did not err in concluding that the genetic analysis of a napkin discarded by Westrom was not a search under the United States or Minnesota Constitutions. The court also found that the circumstantial evidence was sufficient to support Westrom’s convictions. However, the court reversed the second-degree murder conviction and remanded to the district court to vacate that conviction, as it was an error to convict Westrom of both first-degree felony murder and the lesser-included offense of second-degree intentional murder. View "State of Minnesota vs. Westrom" on Justia Law

Tyson Joe Hinckley was convicted of first-degree arson, second-degree burglary, and theft of a motor vehicle. Hinckley had stolen a vehicle from a garage and started a fire that damaged the garage and an adjacent home. He sought to assert a mental-illness defense at trial, submitting multiple psychological reports attesting to his mental illness at the time of his offenses. However, the district court rejected the mental-illness defense, concluding that Hinckley had not provided sufficient evidence that he was acting under a defect in reasoning caused by mental illness at the time of the offenses. Hinckley was found guilty at trial, and the court of appeals affirmed the convictions.The Minnesota Supreme Court reversed the lower courts' decisions, holding that the district court had abused its discretion by denying Hinckley the right to assert a mental-illness defense. The Supreme Court found that the psychological reports submitted by Hinckley provided sufficient evidence to establish a prima facie case of a mental-illness defense. The court concluded that the district court's error was not harmless beyond a reasonable doubt, as it could not be certain that the jury's verdict was surely unattributable to the error. The case was remanded for further proceedings consistent with the Supreme Court's opinion. View "State of Minnesota vs. Hinckley" on Justia Law

Edbert Neal Williams was convicted of first-degree murder and first-degree attempted murder in the death of Genelda Campeau and the attack on her adult granddaughter, S.C. Williams was sentenced to life in prison for murder and received a 180-month consecutive sentence for attempted murder. He appealed, and his convictions were affirmed. In this postconviction proceeding, Williams seeks a new trial or an evidentiary hearing based on new DNA evidence not available at the time of trial. Williams asserts the DNA evidence exonerates him and implicates an alternative perpetrator.Williams had previously filed multiple postconviction relief petitions, all of which were denied. In 2019, Williams filed a motion seeking forensic testing of evidence from the 1996 crime scene. The district court granted the motion, and the Bureau of Criminal Apprehension (“BCA”) analyzed evidence that it had retained from the crime scene. The BCA released three reports in August 2020, September 2020, and November 2022, and a private lab Williams hired released one report in October 2022. Williams asserts that these reports corroborate his claims that he was not at the scene of the crime when it occurred and that an alternative perpetrator killed Genelda.The district court summarily denied his petition. The court concluded that Williams’s petition was barred by the 2-year time limit for postconviction relief petitions set out in Minnesota Statutes section 590.01, subdivision 4(a) (2022), and that neither the newly-discovered-evidence exception nor the interests-of-justice exception to the time bar applied.The Supreme Court of Minnesota affirmed the district court's decision. The court found that the new DNA evidence did not meet the clear and convincing standard for newly discovered evidence and, in fact, some of the additional testing points towards Williams as the perpetrator rather than excludes him. The court also rejected Williams's claim that he is entitled to relief based on the interests-of-justice exception because his mental illness prevented him from timely filing his petition. The court noted that Williams had been sufficiently competent to file his direct appeal from his conviction, postconviction petitions, and appeals from postconviction petitions. View "Williams vs. State of Minnesota" on Justia Law

The case revolves around the interpretation of Minnesota Statutes section 171.177, subdivision 1, which requires law enforcement officers to inform individuals suspected of driving under the influence that refusal to submit to a blood or urine test is a crime. The respondent, Brian Matthew Nash, was pulled over for suspected impaired driving. After failing field sobriety tests, he was arrested and a state trooper obtained a search warrant for a blood or urine test. The trooper informed Nash that refusal to take a test is a crime, and Nash complied. His blood test revealed the presence of a controlled substance, leading to the revocation of his driving privileges.Nash sought judicial review of his license revocation, arguing that the trooper's advisory did not comply with the statutory requirement. The district court rejected Nash's arguments and sustained the revocation. On appeal, the court of appeals reversed, finding that the advisory given to Nash was misleading and an inaccurate statement of law.The Minnesota Supreme Court disagreed with the court of appeals' interpretation of the statute. The court held that the trooper's statement that "refusal to take a test is a crime" satisfied the advisory required by section 171.177, subdivision 1. The court reasoned that the statute does not require officers to inform drivers of all the elements and permutations of what is required before the state may take adverse action against them. The court reversed the decision of the court of appeals and remanded the case for consideration of the other issues raised by Nash in his appeal. View "Nash v. Commissioner of Public Safety" on Justia Law

The case involves the defendant, David Darnell Jones, Jr., who was convicted of second-degree assault after threatening to beat a victim, A.M., while holding a wooden board. The board was approximately 2 inches by 3 inches and 3 feet long. To commit second-degree assault, a defendant must assault another person with a dangerous weapon. The State alleged that Jones brandished the board as a dangerous weapon near the semi-conscious victim, while simultaneously threatening to “beat [A.M.] bloody.” Jones pleaded not guilty and demanded a jury trial.The district court instructed the jury on assault-fear and also instructed the jurors that an object which is neither a firearm nor designed as a weapon can still be considered a dangerous weapon if the defendant intended to use it in a manner likely to produce death or great bodily harm. The jury found Jones guilty of both second- and third-degree assault. The district court convicted Jones of both counts and sentenced him to 39 months in prison for second-degree assault. A divided panel of the court of appeals affirmed Jones’s conviction for second-degree assault but reversed his third-degree assault conviction as a lesser-included offense.The Minnesota Supreme Court affirmed the decision of the court of appeals. The court concluded that Jones’s statements expressing his plan to harm A.M., made while the assault was occurring and as Jones was brandishing the board, are direct evidence of his intent to use the board in a manner likely to produce great bodily harm. The court further concluded that, based on the direct evidence of Jones’s intended use of the board, a jury could reasonably conclude that the board was a dangerous weapon. View "State vs. Jones" on Justia Law

The case revolves around a murder conviction. On February 23, 2021, a bar shooting resulted in the death of Raymond Renteria-Hobbs and injury to another victim, M.P. Police identified Andrew Vernard Glover as the suspect based on security footage showing him at the bar on the night of the murder and his interactions with Renteria-Hobbs before the shooting. The police arrested Glover and, upon searching his residence, found the hat he wore on the night of the shooting, a loaded firearm, and ammunition.At trial, Glover challenged his arrest and the subsequent search of his residence. However, the court held that the police had probable cause to arrest Glover, and the search warrant application for his residence did not materially misrepresent information.Glover also sought to introduce evidence of prior crimes committed by an alleged alternative perpetrator, but the court denied his request, finding those crimes were neither relevant nor material to the charged offense. Glover also argued that the court violated his confrontation rights by denying his request to cross-examine the lead investigator about whether police had investigated unnamed suspects from a prior shooting of one of the victims. The court rejected this argument as well.The jury convicted Glover of first-degree murder during a drive-by shooting, drive-by shooting, and ineligible person in possession of a firearm. Glover appealed, but the Supreme Court of Minnesota affirmed the conviction. The court held that the police had probable cause to arrest Glover, the search of his residence was lawful, the court did not abuse its discretion by denying Glover's motion to admit reverse-Spreigl evidence, and Glover's confrontation rights were not violated. View "State of Minnesota vs. Glover" on Justia Law