Justia Criminal Law Opinion Summaries

In 2001, Respondent was found guilty of first-degree murder while committing or attempting to commit criminal sexual conduct and first-degree premeditated murder. Respondent was a juvenile when he committed the crime. The district court sentenced Respondent to life without the possibility of release (LWOR) under the mandatory sentencing scheme in Minn. Stat. 609.106(2)(1). After the U.S. Supreme Court decided Miller v. Alabama in 2012, Respondent filed a petition for postconviction relief, arguing that his sentence violated the Eighth Amendment. The postconviction court granted Respondent’s petition and resentenced him to life in prison with the possibility of release after thirty years. The Minnesota Supreme Court subsequently issued its decision in Chambers v. State, which held that the Miller rule does not apply retroactively to a juvenile whose sentence of LWOR under section 609.106(2)(1) became final before the Miller rule was announced. Thereafter, in the instant case, the Supreme Court reversed the postconviction court’s order and reinstated the original sentence of LWOR, holding that the postconviction court’s legal conclusion was in direct conflict with Chambers, and the circumstances of this case did not warrant granting relief to Respondent under the Court’s supervisory powers to ensure the fair administration of justice. View "Roman Nose v. State" on Justia Law

After a jury trial, Defendant was found guilty of felony failure to pay child support. After Defendant filed his notice of appeal, the district court issued a warrant for Defendant’s arrest because Defendant failed to appear for a hearing on an alleged probation violation. The State moved to dismiss Defendant’s appeal on the ground that he was a fugitive who had forfeited his right to an appeal. The court of appeals denied the motion on the grounds that Minnesota has not yet adopted the fugitive-dismissal rule. On review, the Supreme Court adopted the fugitive-dismissal rule, holding that appellate courts have the discretion to dismiss an appeal brought by a fugitive. The Court then reversed and directed the court of appeals to dismiss Defendant’s appeal if he did not surrender within ten days, holding that Defendant was a fugitive and his status as a fugitive granted an appellate court the discretionary authority to dismiss his appeal. View "State v. Hentges" on Justia Law

The State charged Respondents with first-degree burglary under Minn. Stat. 609.582 for breaking into a home and allegedly stealing a locked safe that contained a handgun. The district court dismissed the first-degree burglary charges for lack of probable cause, concluding that section 609.582(1)(b), which requires possession of a dangerous weapon during the burglary, requires knowing possession of a dangerous weapon during the burglary. The Supreme Court reversed, holding (1) section 609.582(1)(b) does not include a mens rea requirement with respect to a defendant’s possession of a dangerous weapon; and (2) therefore, the district court erred in reading an additional knowledge requirement into the statute. View "State v. Garcia-Gutierrez" on Justia Law

Defendant was convicted of two counts of aiding suicide in violation of Minn. Stat. 609.215(1), which makes it illegal to intentionally “advise, encourage, or assist another in taking the other’s own life.” Defendant had responded to posts on suicide websites by encouraging the victims to hang themselves, falsely claiming that he would also commit suicide. Defendant appealed, arguing that section 609.215(1) violated the First Amendment. The court of appeals affirmed, holding that the statute prohibited speech that was unprotected by the First Amendment. The Supreme Court reversed, holding (1) the State may prosecute Defendant for assisting another in committing suicide but not for encouraging or advising another to commit suicide, and thus the words “advises” and “encourages” must be severed from the statute as unconstitutional; and (2) because the district court did not make a specific finding on whether Defendant assisted the victims’ suicides, the case must be remanded. View "State v. Melchert-Dinkel" on Justia Law

Respondent was charged by juvenile petition, as both a principal and an accomplice, with criminal sexual conduct and other crimes arising out of the rape of a fourteen-year-old girl. After a hearing, the juvenile court concluded that Respondent had not overcome the presumption in favor of certification to adult court and certified Respondent for prosecution as an adult. The court of appeals reversed, concluding that the juvenile court abused its discretion by failing to expressly weigh the seriousness of the alleged offense and Respondent’s prior record of delinquency separate from other public safety factors and by failing to specifically delineate how its determination of the two factors impacted its certification decision, as required by Minn. Stat. 260B.125. The Supreme Court reversed, holding (1) the court of appeals erroneously interpreted section 260B.125(4); and (2) the juvenile court did not abuse its discretion by concluding that Respondent failed to overcome the presumption in favor of certification. View "In re Welfare of J.H." on Justia Law

Law enforcement officers stopped a truck driven by Thomas Anthony, a suspected drug dealer. Charles Lemert was a passenger in Anthony’s car. Officers ordered Lemert to get out of the truck and proceeded to conduct a pat search of Lemert. Based on the evidence discovered during the pat search, the State charged Lemert with a fifth-degree controlled-substance offense. Lemert moved to suppress the evidence, arguing that the search was unlawful because the officers lacked a reasonable, articulable suspicion that Lemert might have been armed and dangerous. The district court denied the motion and convicted Lemert of the charge. The court of appeals affirmed. The Supreme Court affirmed, holding that, under the circumstances, the officers had a reasonable, articulable suspicion that Lemert might have been armed and dangerous, and therefore, the district court did not err when it denied Lemert’s motion to suppress. View "State v. Lemert" on Justia Law

Defendant was convicted of murder in the first degree while committing domestic abuse and with a past pattern of domestic abuse. Defendant subsequently filed a petition for postconviction relief, arguing, among other things, that there was insufficient evidence to establish a past pattern of domestic abuse beyond a reasonable doubt. After an evidentiary hearing, the postconviction court denied the petition. The Supreme Court affirmed, holding (1) sufficient evidence supported the jury’s finding that Defendant engaged in a past pattern of domestic abuse against the victim; (2) the district court did not err in its jury instructions on a past pattern of domestic abuse; and (3) the district court did not commit plain error by admitting evidence connected to orders for protection obtained by the victim, as Appellant’s substantial rights were not affected by the admission of this evidence. View "Gulbertson v. State" on Justia Law

Appellant was convicted of felony-level failure to provide care and support to his children due to his omission and failure to pay court-ordered child support. The court of appeals affirmed the conviction, concluding (1) the phrase “care and support” in Minn. Stat. 609.375(1) refers exclusively to a person’s financial obligations to a spouse or child; and (2) the district court did not err when it excluded Appellant’s evidence that he had provided nonmonetary care to his children. The Supreme Court reversed, holding (1) to obtain a conviction under section 609.375(1) the State must prove beyond a reasonable doubt that a defendant knowingly omitted and failed to provide both care and support to a spouse or child; and (2) the State did not present any evidence that Appellant knowingly omitted and failed to provide care to his children, and therefore, insufficient evidence supported Appellant’s conviction under the care-and-support statute. View "State v. Nelson" on Justia Law

Respondent, a criminal defendant, successfully filed a motion to suppress, which the State appealed. The court of appeals reversed the order granting the motion to suppress. Defendant filed a motion for attorney fees, requesting that his attorney receive $120 per hour for 30.3 hours of work performed on the appeal. The State opposed the motion, contending that the court was required to use the rate of $50 an hour set in a standing order of the district court to that portion of the work defense counsel performed after the order was issued. The court of appeals granted the amount Respondent requested. The Supreme Court affirmed, holding that, under the circumstances, the court of appeals did not abuse its discretion in awarding Respondent a consistent hourly rate of $120 per hour for attorney fees and awarding him his full attorney-fee request. View "State v. Williams" on Justia Law

After a jury trial, Appellant was found guilty of first-degree murder of a peace officer, four counts of first-degree assault, and other offenses connected with the shooting death of a county deputy sheriff officer. The Supreme Court reversed one of the first-degree assault convictions but otherwise affirmed, holding (1) the district court did not abuse its discretion when it transferred venue to Polk County; (2) the murder prosecution was not barred by the common law “year-and-a-day rule” because the victim died eighteen months after the shooting, as the year-and-a-day rule does not apply to the Minnesota law of homicide; (3) the district court did not abuse its discretion by admitting into evidence certain photographs; and (4) the evidence was insufficient to support Defendant’s conviction on one of the first-degree assault counts. View "State v. Fairbanks" on Justia Law