Justia Criminal Law Opinion Summaries

The State filed a complaint against Defendant charging him with third- and fourth-degree criminal sexual conduct. Defendant waived his right to a jury trial during a pretrial hearing. Thereafter, the State filed an amended complaint adding a charge of first-degree criminal sexual conduct. Defendant did not personally waive his right to a jury trial on the amended charge. Defendant was subsequently found guilty of all three counts. Defendant appealed, arguing that the district court erred when it failed to obtain a personal waiver of his right to a jury trial after the State amended the complaint. The court of appeals affirmed Defendant’s first-degree sexual conduct conviction. The Supreme Court reversed the court of appeals, vacated Defendant’s conviction for first-degree criminal sexual conduct, and remanded, holding (1) when the State charges a defendant with an additional offense after the defendant has waived his or her right to a jury trial, the court must obtain a new waiver before dispensing with a jury; and (2) in this case, the district court’s failure to obtain a personal waiver of Defendant’s right to a jury trial on the charge of first-degree criminal sexual conduct constituted a plain error that affected Defendant’s substantial rights. View "State v. Little" on Justia Law

Appellant was convicted for the first-degree premeditated murder of Devan Hawkinson. Appellant and Hawkinson were friends before Hawkinson was murdered. On appeal, Appellant argued that the district court erred by admitting evidence of his past conduct and relationship with Hawkinson, contending that the evidence violated his rights under the Confrontation Clause because it included testimonial statements that Hawkinson made to the police before his death and that it was irrelevant. The Supreme Court affirmed, holding (1) any error in admitting the evidence was harmless; and (2) none of the claims raised in Appellant’s pro se briefs entitled him to relief. View "State v. Rossberg" on Justia Law

Appellant pleaded guilty to one count of aiding and abetting first-degree premeditated intentional murder. The district court sentenced Appellant to a mandatory life sentence with the possibility of release after thirty years. More than eight years after Appellant was sentenced, the district court issued its restitution order, which ordered that Defendant be jointly and severally liable for paying $23,060 in restitution along with several of his codefendants. The Supreme Court affirmed in part, vacated in part, and remanded, holding (1) Defendant forfeited his argument that the restitution order improperly included restitution for losses for which an insurance company had already reimbursed the victim’s estate; (2) the order improperly calculated the restitution Appellant and his codefendants should pay for damage done to the victim’s car; and (3) the district court had statutory authority to order that the codefendants were jointly and severally liable for the restitution award. View "State v. Johnson" on Justia Law

Appellant argued that he is entitled to a new trial because the court found that the judge who presided over his conviction and sentencing failed to reside in her judicial district from July 1, 2009, to September 30, 2009. The court held that Minn. Stat. 351.02(4) does not apply to a district court judge residing in Minnesota but outside her judicial district because a district court judge does not hold a "local" office as that term is used in the statute. Accordingly, because this portion of the statute does not apply to the judge in this case, the court affirmed. View "State v. Irby" on Justia Law

Defendant was convicted of stalking and violating an order for protection. The district court imposed a sentence for each offense and ordered the two sentences to be served consecutively. The court held that Minn. Stat. 609.035, subd. 1, generally limits the number of sentences a defendant may receive for multiple convictions arising out of a single course of conduct; Minn. Stat. 518B.01, subd. 16, does not create an exception to Minn. Stat. 609.035, subd. 1; if separate sentences are not precluded by Minn. Stat. 609.035, subd. 1, the fact that the convictions involve a single course of conduct does not prevent a district court from imposing permissive consecutive sentences in accordance with Minn. Sent. Guidelines II.F.2.b. In this case, because the court concluded that the district court and the court of appeals erred by conflating two distinct issues - whether separate sentences may be imposed and how separate sentences should be served - the court reversed and remanded with instructions to vacate the sentence imposed for violating an order of protection. View "State v. Jones" on Justia Law

After a jury trial in 1992, Appellant was found guilty of two counts of first-degree murder and two counts of attempted first-degree murder. Appellant was fifteen years old at the time. Under a mandatory sentencing scheme, the district court imposed life sentences with the possibility of release after thirty years for the first-degree murder convictions. After the United States Supreme Court decided Miller v. Alabama in 2012, Appellant filed a postconviction motion to correct his sentence, arguing that his sentence violated the rule announced in Miller. The postconviction court denied the motion, concluding that Appellant’s sentence was lawful because Miller was not retroactive. The Supreme Court affirmed without reaching the issue of Miller’s retroactivity, holding that Miller did not make the sentencing scheme at issue here unlawful because the mandatory sentencing scheme did not require life imprisonment without the possibility of release. View "Ouk v. State" on Justia Law

After a jury trial, Appellant was found guilty of first-degree premeditated murder and sentenced to a term of life imprisonment. The Supreme Court affirmed on appeal. After Appellant’s first petition for postconviction relief was denied, Appellant filed the petition for postconviction relief at issue in this appeal. Defendant requested an evidentiary hearing and court-appointed counsel to assist with his petition. The postconviction court denied Appellant’s requests and summarily denied the petition, concluding that the petition was procedurally barred. The Supreme Court affirmed, holding that the postconviction court did not abuse its discretion denying the petition without appointing counsel and without holding an evidentiary hearing. View "Hughes v. State" on Justia Law

After a jury trial, Appellant was convicted of first-degree premeditated murder and sentenced to life in prison without the possibility of release. The Supreme Court affirmed Appellant’s conviction, holding (1) Appellant’s constitutional challenges to the first-degree premeditated murder statute were procedurally barred; (2) sufficient evidence supported Appellant’s conviction; (3) trial court did not err in instructing the jury on premeditation; (4) any error in allowing Appellant’s former wife to testify did not prejudice Appellant; and (5) any error in the admission of hearsay statements from certain witnesses under the residual hearsay exception was harmless. View "State v. Moore" on Justia Law

The State filed a delinquency petition charging Appellant, who was then fourteen years old, with first-degree felony murder (drive-by shooting), second-degree felony murder (drive-by shooting), and attempted first-degree felony murder (drive-by shooting). Defendant pled guilty to the murder charges, but the Supreme Court vacated the convictions. On remand, the case proceeded to trial, and a jury found Appellant guilty of all three counts. The Supreme Court affirmed, holding (1) the district court had original and exclusive jurisdiction over Appellant’s offenses; (2) sufficient evidence supported Appellant’s convictions; (3) assuming that the district court improperly instructed the jury on the elements of drive-by shooting, Appellant did not establish that the error affected his substantial rights; (4) Appellant’s mandatory life sentence with the possibility of release was not unconstitutional under the principles of Miller v. Alabama; (5) the district court did not abuse its discretion by imposing a longer sentence upon Appellant after his trial and conviction; and (6) the postconviction court did not err when it summarily denied Appellant’s petition for postconviction relief. View "State v. Vang" on Justia Law

One day before Appellant was scheduled to be released from prison, where he served a sentenced imposed following a guilty plea to third-degree criminal sexual conduct, Sibley County filed a petition to have Appellant civilly committed as a sexually dangerous person. After a commitment hearing, the district court concluded that clear and convincing evidence demonstrated that Appellant met the statutory requirements for commitment as a sexually dangerous person. The court of appeals affirmed. The Supreme Court reversed, holding (1) the risk of harmful sexual conduct occurring must be “highly likely” based on consideration of the factors set forth in In re Linehan and all relevant evidence; and (2) because it could not be determined whether the district court adhered to the Linehan factors after considering the other evidence, reconsideration of the unique and specific facts of Appellant’s case was warranted. View "In re Civil Commitment of Ince" on Justia Law