Justia Criminal Law Opinion Summaries

After a bench trial, Defendant was found guilty of four counts of first-degree murder and two counts of second-degree murder. Defendant was sentenced to two consecutive sentences of life imprisonment without the possibility of release on the first-degree murder counts. Defendant later filed a petition and an amended petition for postconviction relief. The district court denied the petition on October 24, 2014, finding that one claim failed on its merits and that the other claim was Knaffla-barred. Defendant then filed an amended postconviction petition, which the district court denied on October 28, 2014. Defendant filed motions to reconsider the orders denying his petition and amended petition for postconviction relief. On January 16, 2015, the district court denied both motions. Defendant appealed from both the October 2014 orders and from the January 2015 order. The Supreme Court dismissed the appeal for lack of jurisdiction because Defendant’s appeal from the October 2014 orders was untimely and because the district court’s January 2015 order was not appealable at all. View "Hohenwald v. State" on Justia Law

After a jury trial, Defendant was found guilty of first-degree felony murder and attempted first-degree premeditated murder. Defendant was sentenced to life in prison for the murder. The Supreme Court stayed Defendant’s appeal so he could pursue postconviction relief. The district court denied Defendant’s petition for postconviction relief without holding an evidentiary hearing. On appeal, Defendant alleged the same five errors that he raised in his postconviction petition and argued that the postconviction court erred by denying his petition without granting an evidentiary hearing. The Supreme Court affirmed Defendant’s convictions and the summary denial of Defendant’s petition for postconviction relief, holding (1) Defendant was not entitled to a new trial on any of his claims; and (2) the postconviction court did not abuse its discretion in denying Defendant’s petition without a hearing. View "State v. Whitson" on Justia Law

After a jury trial, Defendant was found guilty of two counts of second-degree murder and two counts of first-degree premeditated murder. Defendant was sentenced to two concurrent life sentences without the possibility of release. After a restitution hearing, the district court denied the victims’ families’ requests for restitution to cover the estimated cost of a headstone for each victim. The Supreme Court affirmed Defendant’s first-degree murder convictions and reversed the district court on the issue of restitution, holding that the district court (1) did not commit reversible error when it denied Defendant’s motion to dismiss the indictment for individual and cumulative errors; (2) did not violate Defendant’s Sixth Amendment right to a public trial when it closed the courtroom to the public to discuss its written order on the admissibility of certain testimony; (3) did not commit prejudicial error in excluding four pieces of evidence; (4) did not commit misconduct in his closing argument; and (5) erred by allowing Defendant to challenge the restitution request for the headstones under Minn. Stat. 611A.045(3)(a). View "State v. Smith" on Justia Law

After the first phase of a bifurcated trial on stipulated facts, Defendant was found guilty of two counts of first-degree premeditated murder. After the second phase of the bifurcated trial, in which the district court heard expert psychiatric testimony, the district court concluded that Defendant failed to establish a mental illness defense. Defendant was sentenced to life in prison without the possibility of release. On appeal, Defendant challenged the rejection of his mental illness defense. The Supreme Court affirmed, holding that the district court did not clearly err in finding that Defendant failed to establish, by a preponderance of the evidence, that he did not know that his acts were morally wrong at the time of the murders. View "State v. Roberts" on Justia Law

After a second jury trial before Judge Harvey Ginsberg, Defendant was convicted of first-degree premeditated murder. The Supreme Court affirmed Defendant’s conviction on direct appeal. In 2003, Defendant filed his first petition for postconviction relief. The postconviction court denied the petition. Before the Supreme Court decided the appeal from the denial of Defendant’s postconviction petition, the Court removed Judge Ginsberg from office. The Court subsequently affirmed the postconviction court’s judgment denying relief to Defendant. In 2014, Defendant filed a petition for postconviction relief based on Judge Ginsberg’s removal from office. The postconviction court denied the petition without holding an evidentiary hearing, concluding that the petition was both untimely filed and procedurally barred. The Supreme Court affirmed, holding that the postconviction court did not err in denying Defendant’s second petition or postconviction relief without holding an evidentiary hearing where Defendant filed his petition after the expiration of the statutory two-year limitations period, and the statutory interests-of-justice exception does not apply. View "Taylor v. State" on Justia Law

Defendant pleaded guilty pursuant to an Alford plea to fifth-degree criminal sexual conduct. Jane Doe subsequently sued Defendant, alleging that he committed sexual battery and sexual abuse based on the conduct that gave rise to the criminal charges. Prior to trial, Defendant brought a motion in limine to prevent Doe from introducing evidence of the Alford plea. The district court granted the motion, concluding that any mention of the Alford plea would be substantially more prejudicial to Defendant than probative to Doe’s case. After a jury trial, Defendant was found not liable for sexual assault and battery. The Supreme Court affirmed, holding that the district court (1) did not abuse its discretion by declining to admit Defendant’s Alford plea under Minn. R. Evid. 403; and (2) did not abuse its discretion when it did not allow Defendant’s Alford plea to be admitted for impeachment purposes. View "Jane Doe 136 v. Liebsch" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder. The Supreme Court affirmed. Appellant later filed his current petition for postconviction relief alleging that a witness had recanted his trial testimony. After an evidentiary hearing to determine the credibility of the alleged recantation, the postconviction court denied the petition, concluding that “it was not well satisfied that the trial witness’s testimony was false.” The Supreme Court affirmed, holding (1) Appellant failed to prove that the State substantially interfered with the decisions of Appellant’s witnesses about whether to testify at the postconviction hearing; and (2) the postconviction court did not abuse its discretion by refusing to grant use immunity to Appellant’s witnesses or by finding that Appellant presented insufficient evidence to warrant a new trial. View "McKenzie v. State" on Justia Law

After a jury trial in 2003, Appellant was found guilty of first degree murder and sentenced to life imprisonment without the possibility of release. In 2014, Appellant filed his sixth postconviction petition, alleging newly discovered evidence, juror misconduct, and that cumulative errors required a new trial in the interests of justice. The postconviction court denied Appellant’s petition without holding an evidentiary hearing. The Supreme Court affirmed, holding that the postconviction court did not abuse its discretion in denying the petition, as the record conclusively showed that Appellant’s claims were either harmless beyond a reasonable doubt, procedurally barred, or meritless. View "Colbert v. State" on Justia Law

In 1987, after a jury trial, Appellant was convicted of first-degree murder while committing criminal sexual conduct. Appellant was sentenced to life in prison. In 2014, Appellant brought a motion to correct his sentence. The postconviction court treated Appellant’s motion as a petition for postconviction relief and denied it because of Appellant’s failure to file it until after the two-year postconviction statute of limitations had expired. The Supreme Court affirmed, holding that the postconviction court did not abuse its discretion when it denied relief to Appellant on the grounds that the statute of limitations had expired. View "Wayne v. State" on Justia Law

An airport police narcotics investigator removed a package, which was addressed to Defendant, from a conveyor belt at the UPS mail area at the Minneapolis-Saint Paul International Airport, and placed the package on the floor. A trained narcotics-detection dog was brought into the area and alerted to the package. Based on the dog’s alert, an airport police narcotics investigator obtained a warrant authorizing him to open and search the package, which contained cocaine and methamphetamine. Appellant was charged with two counts of a first-degree controlled substance crime. Appellant filed a motion to suppress, arguing that the movement of the package to the floor constituted a seizure, that the dog sniff constituted a search, and that the package was seized and searched without a reasonable, articulable suspicion of criminal activity. The district court denied Petitioner’s motion, concluding that the detention and dog sniff did not constitute a search or seizure. The court of appeals affirmed on other grounds, determining that there was both a search and a seizure but that there was reasonable, articulable suspicion for both. The Supreme Court affirmed on the same basis as the district court, holding that there was neither a search nor a seizure under the facts of this case. View "State v. Eichers" on Justia Law