Justia Criminal Law Opinion Summaries

Defendant, who was HIV positive, engaged in consensual anal intercourse. Defendant was subsequently charged with attempted first-degree assault by transferring a communicable disease for violating Minn. Stat. 609.2241(2). A jury found Defendant violated section 609.2241(2)(2), which applies to the "transfer of blood, sperm, organs, or tissue." The court of appeals reversed the conviction, concluding that section subdivision 2(2) applies only to medical procedures instead of applying to acts of sexual conduct. The Supreme Court affirmed, holding (1) subdivision 2(2) applies only to the donation or exchange for value of blood, sperm, organs, or tissue; and (2) because Defendant's conduct indisputably did not involve the donation or exchange for value of his sperm, subdivision 2(2) was inapplicable to Defendant's conduct. View "State v. Rick" on Justia Law

After a jury trial, Defendant was convicted of criminal vehicular homicide for causing the death of ninety-three-year-old Edith Schouveller in a motor vehicle accident. The accident occurred on March 28, 2010. Schouveller was transported to the hospital with several life-threatening injuries. For the next twenty-two days, Schouveller was either hospitalized or in a nursing home. Schouveller developed lung problems while in the hospital, which led to pneumonia. On April 19, 2010, Schouveller experienced acute respiratory failure. Doctors determined that she needed to be placed on a respirator in order to continue to live, but relying on Schouveller's living will, the doctors declined to place her on respiratory support. Schouveller died that evening. The Supreme Court affirmed Defendant's conviction, holding (1) the district court properly instructed the jury on causation; (2) the State presented sufficient evidence to demonstrate a causal chain between the injuries Shouveller sustained in the accident and the pneumonia and aspiration that ultimately led to her death; and (3) the evidence was sufficient for the jury to conclude that the do-not-resuscitate order in Souveller's living will was not a superseding cause of her death. View "State v. Smith" on Justia Law

After a jury trial in 1994, Defendant was convicted of first-degree murder and sentenced to life in prison with the possibility of release. Seven months later, Defendant pleaded guilty to second-degree attempted murder. The court sentenced Defendant to an additional seventy-two months in prison to run consecutively to his life sentence. In 2012, Defendant filed a pro se motion to correct his sentence under Minn. R. Crim. P. 27.03(9). The district court treated the motion as a petition for postconviction relief and then denied the motion on the grounds it was time barred and procedurally barred. The Supreme Court affirmed, holding that even if Defendant's motion was not time barred or procedurally, barred, his argument that the overall length of his imprisonment should be reduced failed on the merits. View "Townsend v. State" on Justia Law

After a jury trial, Defendant was convicted of nine counts, including one count of first-degree premeditated murder and two counts of attempted first-degree premeditated murder, stemming from an incident in which Defendant fired a semiautomatic rifle at Joseph Rivera and two of Rivera's friends. The Supreme Court affirmed, holding that the district court did not err when it (1) denied Defendant's pretrial motion to dismiss the indictment, as any alleged misconduct by the State did not substantially influence the grand jury's decision to indict; (2) admitted Defendant's taped statement to police, as the statement was voluntary made; (3) admitted a photograph of Rivera as a child, as the photograph was admissible as spark of life evidence; (4) denied Defendant's motion for a mistrial based on a law enforcement officer's testimony that Defendant was truant and once swore at a teacher in high school; and (5) denied Defendant's request for surrebuttal closing argument, because even if the district court erred in denying the request, the error was harmless beyond a reasonable doubt. View "State v. Morrow" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder by drive-by shooting and first-degree premeditated murder. Defendant appealed, arguing that the trial court erred in admitting out-of-court statements made by his wife and cell phone records obtained without a warrant. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion in admitting Defendant's wife's statement under Minn. R. Evid. 807; and (2) the district court did not err in finding Defendant had no subjective expectation of privacy in the cell phone records at issue under the Supreme Court's decision in State v. Gail, and therefore, the admission of the cell phone records did not violate Defendant's constitutional rights. View "State v. Griffin" on Justia Law

After a jury trial, Defendant was convicted of third-degree criminal sexual conduct and sentenced to forty-eight months in prison. As part of the sentencing order, the trial court ordered Defendant to pay restitution. More than ninety days after entry of the order imposing Defendant's initial sentence, the court amended the restitution portion of Defendant's initial sentence. The State appealed the amended sentencing order, but the court of appeals dismissed the appeal because it was not filed within ninety days after the initial imposition of Defendant's sentence. The Supreme Court reversed, holding (1) the issuance of an order amending the restitution portion of a sentence constitutes a "sentence imposed" within the plain language of the relevant statute, such that the State had ninety days to appeal the amended sentencing order from the date it was entered; and (2) because the State appealed the amended sentencing order within ninety days, the appeal was timely. Remanded. View "State v. Borg" on Justia Law

After a jury trial, Appellant was convicted of first-degree premeditated murder and second-degree murder. Appellant appealed, asserting, among other issues, that the trial court erred in denying his motion to suppress statements he made to police because he was in custody when he made the statements and had not received a Miranda warning. The Supreme Court affirmed Defendant's convictions, holding (1) any error the trial court may have made in denying Appellant's motion to suppress statements he made to police was harmless beyond a reasonable doubt; and (2) the evidence was sufficient to support Appellant's conviction. View "State v. Sterling" on Justia Law

The district court issued domestic abuse no contact orders pursuant to Minn. Stat. 629.75(1) prohibiting Appellant from contacting his wife. After Appellant allegedly contacted his wife, he was charged with two felony violations. Appellant moved to dismiss the charges, contending that section 629.75(1) violates due process because it fails to provide adequate notice and an opportunity to be heard and encourages arbitrary and discriminatory enforcement. The district court granted Appellant's motions, concluding that the statute provides defendants with no procedural due process and grants judges unfettered discretion in determining whether to issue a domestic abuse no contact order. The court of appeals reversed. The Supreme Court affirmed, holding that, on its face, the statute (1) ensures that a defendant will receive notice of the conditions to be imposed and an opportunity to challenge those conditions in a constitutionally sufficient proceeding before the court imposes a domestic abuse no contact order; and (2) is not unconstitutionally vague because it does not encourage arbitrary and discriminatory enforcement. View "State v. Ness" on Justia Law

The State charged Defendant with two counts of second-degree murder for the stabbing death of Tina San Roman and second-degree assault and attempted second-degree murder for the stabbing of a second victim, O.A.R. A jury acquitted Defendant on the murder counts but deadlocked on the two other counts relating to the attack on O.A.R. In preparation for a retrial on the unresolved counts, the district court (1) excluded the State's evidence related to San Roman's death, concluding that the evidence would mislead the jury and substantially prejudice Defendant; then (2) granted Defendant's motion to dismiss the remaining counts, concluding (i) Defendant could not present his alternative-perpetrator defense without using evidence relating to San Roman's death, and (ii) the exclusion of Defendant's alternative-perpetrator evidence would violate Defendant's right to present a complete defense. The Supreme Court reversed and remanded, holding that the exclusion of the alternative-perpetrator evidence did not violate Defendant's due process right to present a complete defense. View "State v. Pass " on Justia Law

Appellant was convicted of murder and sentenced to life in prison. The Supreme Court affirmed the conviction. After unsuccessfully filing four petitions for postconviction relief, Appellant filed a "Motion for DNA Analysis" under Minn. Stat. 590.01(1)(a) requesting DNA testing of the victim's underwear. The postconviction court construed Appellant's motion as his fifth petition for postconviction relief and found the petition was procedurally barred. The Supreme Court affirmed without addressing the issue of whether the postconviction court erred when it treated Appellant's motion as a petition for postconviction relief, holding (1) Appellant's motion for DNA testing failed to satisfy the requirements of Minn. Stat. 590.01(1)(a) as a matter of law; and (2) even if it was proper to treat Appellant's motion as a petition for postconviction relief, Appellant's claim was time-barred. View "Wayne v. State" on Justia Law