Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of felony domestic assault-harm under Minn. Stat. 609.2242, subds. 1(2), 4, holding that there was no error in the proceedings below and that the evidence was sufficient to support the conviction.On appeal, the court of appeals concluded that the district court erred by instructing the jury that Defendant could use reasonable force to resist an "assault against the person" rather than to resist any "offense against the person" but that the error was not plain and that sufficient evidence supported the conviction. The Supreme Court affirmed, holding (1) use of nonlethal self-defense under section 609.06, subd. 1(3) requires a person to resist an offense carrying the threat of bodily harm; (2) the district court's use of the phrase "assault against the person" in the jury instruction at issue was not error; and (3) the evidence was sufficient to support Defendant's conviction. View "State v. Lampkin" on Justia Law

The Supreme Court affirmed the decision of the district court summarily denying Appellant's petition for postconviction relief without an evidentiary hearing, holding that Appellant was conclusively entitled to no relief on his claims even if the facts alleged were proven by a preponderance of the evidence.Appellant, who was imprisoned for first-degree premeditated murder, filed a petition seeking postconviction relief and an evidentiary hearing, arguing that he was deprived of his Sixth Amendment right to effective assistance of appellate counsel in his direct appeal. The district court summarily denied relief. The Supreme Court affirmed, holding that the district court did not abuse its discretion in denying the postconviction petition without an evidentiary hearing. View "Woodard v. State" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree premeditated murder and his sentence of life in prison without the possibility of release, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held (1) the district court did not violate Defendant's Sixth Amendment right to confrontation when it admitted the victim's dying declarations into evidence during the jury trial, and this Court reaffirms that dying declarations are an exception to the Confrontation Clause; (2) the district court did not violate Defendant's Fifth Amendment right to counsel by denying Defendant's motion to suppress his statements to police officers because Defendant validly waived his invoked right to counsel; and (3) there was no reasonable possibility that the admission of Spreigl evidence related to a prior assault charge into evidence significantly affected the verdict. View "State v. Buchan" on Justia Law

The Supreme Court reversed the judgment of the court of appeals denying Defendant's motion for a new trial, holding that the record was insufficient to determine whether Defendant's right to a public trial was violated due to restrictions put in place by the district court arising from the COVID-19 pandemic.In December 2019, Defendant was charged with first-degree aggravated robbery. Because of the restrictions placed on trials due to the pandemic the county submitted a trial plan that excluded all spectators from the courtroom but included a one-way video feed that would broadcast the trial in an adjacent courtroom. The trial court overruled Defendant's objection, and the trial proceeded. After Defendant was convicted he moved for a new trial. The court of appeals denied the motion. The Supreme Court reversed, holding that additional findings were required on the decision to close the courtroom before it could be determined whether Defendant's public trial right was violated. View "State v. Bell" on Justia Law

In this interlocutory appeal, the Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court granting Defendant's motion to suppress statements recorded on a body-worn camera, holding that the district court did not abuse its discretion in determining that the statements should be suppressed.In response to a domestic disturbance 911 call law enforcement officers found A.H. locked out of her apartment while Defendant was inside, and A.H. told the officers that Defendant had assaulted her both in the present and in the past. These statements were recorded by an officer's body-worn camera. Defendant was subsequently charged with one count of misdemeanor domestic assault. The district court granted Defendant's motion to suppress the body-worn camera recording on the grounds that their admission would violate Defendant's constitutional right to confrontation. The court of appeals affirmed. The Supreme Court affirmed, holding that the district court (1) did not abuse its discretion in determining that A.H.'s statements did not qualify as excited utterances under Minn. R. Evid. 802(2); and (2) properly suppressed the statements as inadmissible hearsay. View "State v. Tapper" on Justia Law

The Supreme Court reversed Defendant's conviction of first-degree premeditated murder and second-degree intentional murder following a jury trial, holding that the district court erred in entering a conviction for the lesser-included offense of second-degree intentional murder.After the trial, the district court entered judgment of convictions for both first-degree and second-degree murder but only imposed a sentence for the first-degree murder conviction. The Supreme Court held (1) the evidence was sufficient to prove the element of premeditation for the first-degree murder offense; (2) assuming, without deciding, that the district court erred by failing to identify a certain individual as an accomplice, the failure did not affect Defendant's substantial rights; (3) the district court did not commit any other reversible error in managing the trial and the jury instructions; and (4) the entry of a judgment of conviction for the second-degree intentional murder offense violated Minn. Stat. 609.04, subd. 1. View "State v. Gilleylen" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Appellant's second petition for postconviction relief, holding that Appellant was not entitled to relief on his allegations of error.After a jury trial, Appellant was convicted of first-degree premeditated murder and sentenced to life imprisonment without the possibility of release. The Supreme Court affirmed the conviction and the denial of Appellant's initial petition for postconviction relief. Thereafter, Appellant filed another postconviction petition. The postconviction court summarily denied the petition and denied Appellant's motion to compel discovery. On appeal, Appellant argued, among other things, that his appellate counsel provided ineffective assistance. The Supreme Court affirmed, holding that Appellant was conclusively entitled to no relief. View "Allwine v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Appellant's motion to correct his sentence under Minn. R. Crim. P. 27.03, subd. 9, holding that Appellant's sentence of life imprisonment was mandated by Minn. Stat. 609.185(1).Appellant pleaded guilty to an amended count for first-degree intentional murder while committing a kidnapping and second-degree intentional murder. The district court ultimately convicted Appellant of first-degree premeditated murder and dismissed the second-degree murder count. In this action arising from Defendant's third motion to correct his sentence Defendant argued that the district court violated his due process right by sentencing him to a longer sentence than that recommended in the sentencing worksheet completed for the charge of second-degree murder. The district court concluded that the failure to file a sentencing worksheet for the charge of first-degree murder does not cause a defendant's sentence to be unauthorized or a defendant's due process rights to be violated. The Supreme Court affirmed, holding that there was no error. View "Johnson v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court granting Defendant's motion to dismiss Plaintiff's action brought under 42 U.S.C. 1983 alleging that Minnesota's continuing predatory-offender registration requirements violated his rights under the federal and state constitutions, holding that there was no error.More than a decade after he pleaded guilty to second-degree assault and was required to register as a predatory offender under Minn. Stat. 243.166, subd. 1b Plaintiff brought this action. The district court concluded that the statutory limitations period of six years under Minn. Stat. 541.05, subd. 1(5) barred Plaintiff's section 1983 claims and that the continuing-violation doctrine does not apply to predatory-offender registration requirements. The court of appeals affirmed. The Supreme Court affirmed, holding that the continuing-violation doctrine did not toll the statute of limitations for Plaintiff's claims. View "Franklin v. Evans" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of first-degree arson under Minn. Stat. 609.561, subd. 1, holding that the evidence provided at trial was sufficient to support Defendant's conviction.On appeal, Defendant argued that the word "unlawfully" in the first-degree arson statute created an element of the offense that the State must prove beyond a reasonable doubt and that the State failed establish all of the elements of his crime by failing to present evidence to show that the burning of his house was "unlawful." The court of appeals affirmed the conviction. The Supreme Court affirmed, holding (1) under section 609.561, the State must prove that a person set a fire in a manner not authorized by law as an element of first-degree arson; and (2) the trial court failed properly to instruct the jury, but there was no reasonable likelihood that the jury would have reached a different result had it been properly instructed that the State was required to prove that Defendant started the fire unlawfully. View "State v. Beganovic" on Justia Law