Justia Criminal Law Opinion Summaries

After a bench trial, Defendant was convicted of third-degree possession of a controlled substance. Defendant appealed, arguing that the district court erred by denying his motion to suppress the heroin seized from the car he was driving on the grounds that the police unlawfully searched the car without a warrant. The court of appeals reversed, concluding that the police did not have probable cause to arrest Defendant or to search his car. The Supreme Court reversed, holding that the warrantless search of Defendant’s car was lawful under the automobile exception because there was probable cause to believe that Defendant’s car contained contraband, and therefore, the district court properly denied Defendant’s motion to suppress. View "State v. Lester" on Justia Law

After a jury trial, Appellant was found guilty of first-degree murder while committing child abuse, second-degree felony murder, and second-degree manslaughter. The district court imposed a life sentence with eligibility for supervised release after thirty years. The Supreme Court affirmed the conviction, holding (1) the jury instruction describing felony malicious punishment of a child as a type of child abuse was plainly erroneous, but Appellant failed to establish that the erroneous jury instruction affected her substantial rights; (2) assuming that the district court abused its discretion when it allowed a state expert to testify that biting a child is a “particularly vicious” form of child abuse, there was no reasonable likelihood that the testimony significantly affected the verdict in this case; and (3) the prosecutor made improper remarks during closing argument, but the prosecutorial misconduct did not affect Appellant’s substantial rights. View "State v. Peltier" on Justia Law

After a jury trial, Defendant was found guilty of three counts of first-degree murder while committing first-degree criminal sexual conduct. Defendant was sentenced to life imprisonment without the possibility of release. Thereafter, Defendant filed a petition for postconviction relief, alleging that the district court committed three errors entitling him to relief. The postconviction court denied relief on all grounds. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion when it denied Defendant’s request to introduce alternative-perpetrator evidence; (2) the district court did not err when it denied Defendant’s request for a lesser-included-offense instruction on second-degree intentional murder; and (3) the trial judge presiding at Defendant’s jury trial was not disqualified based on an appearance of partiality. View "Troxel v. State" on Justia Law

After a jury trial, Appellant was convicted of first-degree premeditated murder and sentenced to mandatory life imprisonment. The Supreme Court affirmed on appeal and affirmed the denial of Appellant’s first and second postconviction petitions. This appeal arose from the postconviction court’s summary denial of Appellant’s third and fourth petitions for postconviction relief on the grounds that the petitions were untimely. The Supreme Court affirmed, holding that the postconviction court did not abuse its discretion by determining that Appellant’s third petition was untimely under Minn. Stat. 590.01(4)(c) and that Appellant’s fourth postconviction petition was untimely under Minn. Stat. 590.01(4)(b)(2). View "Rhodes v. State" on Justia Law

During a traffic stop, Defendant failed two sobriety tests. Defendant provided a weak breath sample and refused to provide a second breath sample in violation of Minn. Stat. 169A.20(2). Defendant was subsequently charged with first-degree refusal to submit to testing and first-degree driving under the influence. Defendant pleaded guilty to the refusal-to-test charge. Defendant appealed, arguing that the implied-consent law was unconstitutional and that his conviction was invalid because district court failed fully to comply with the provisions of Minn. R. Crim. P. 26.01(4). The court of appeals affirmed. The Supreme Court affirmed, holding that the district court committed plain error by failing to fully comply with the provisions of Rule 26.01(4), but Defendant failed to show prejudice to his substantial rights and was therefore not entitled to relief based on this error. View "State v. Myhre" on Justia Law

After a jury trial, Defendant was convicted of one count of first-degree premeditated murder for the benefit of a gang and two counts of attempted first-degree premeditated murder for the benefit of a gang. The convictions arose from a drive-by shooting. The Supreme Court affirmed Defendant’s convictions, holding that the district court (1) did not commit prejudicial error when it admitted evidence of a prior drive-by shooting incident that led to Defendant’s prior conviction of attempted murder; (2) did not abuse its discretion when it permitted the State to introduce testimony on gangs from an expert witness; and (3) did not err in its instruction on reasonable doubt because it used language the Supreme Court approved in State v. Smith, rather than the language of the pattern jury instruction. Also, Defendant was not entitled to relief based on any of the claims contained in his pro se brief. View "State v. Thao" on Justia Law

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 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