Justia Criminal Law Opinion Summaries

The case revolves around the interpretation of the term "resources" as used in the criminal restitution statute, Minnesota Statutes section 611A.045, subdivision 1(a)(2). Specifically, the case examines whether the equity in a defendant's home, which he co-owns with his spouse, can be considered as a "resource" when awarding restitution. The appellant, Joshua Henry Baion Cummings (Baion), was convicted of one count of theft by false representation and was ordered to pay restitution. The district court considered the equity in Baion’s home as one of his resources when determining the amount of restitution. Baion appealed, arguing that the equity in a home owned with a non-defendant spouse cannot be considered a resource under the restitution statute. The Court of Appeals affirmed the district court's decision. The Minnesota Supreme Court also affirmed, holding that the term “resources” in the restitution statute unambiguously means useful and valuable possessions, and that home equity, even when the home is co-owned with a non-defendant spouse, may be such a possession. View "State v. Cummings" on Justia Law

In July 1998, Ronald Lewis Greer was implicated in the murder of Kareem Brown by at least five witnesses. He was charged with one count of first-degree murder and one count of second-degree murder. Greer claimed he was not the shooter and that he was at a friend's house at the time of the murder, but a jury found him guilty of both charges in May 1999. Greer was sentenced to life in prison, and on appeal, the conviction was upheld. Over the next few years, Greer filed three petitions for postconviction relief, all of which were denied.In 2021, Greer filed a motion to correct his sentence, arguing that his sentence was unlawful as he was sentenced for two degrees of the same crime. The district court granted Greer's motion in part, vacating his second-degree murder conviction. Greer appealed this decision, claiming that the court should have held a sentencing hearing when it vacated his second-degree murder conviction. This appeal was denied.In 2023, Greer filed a fourth petition for postconviction relief, asking the district court to vacate his first-degree murder conviction, reinstate his second-degree murder conviction, and resentence him. The district court denied Greer's petition, citing it as time-barred under Minnesota Statutes section 590.01, subdivision 4 (2022), and procedurally barred under the rule announced in State v. Knaffla.In a decision by the Supreme Court of the State of Minnesota, the court affirmed the district court's decision. The court held that Greer's petition was time-barred under Minnesota Statutes section 590.01, subdivision 4 (2022), as it was filed more than two years after the later of the entry of judgment of conviction or sentence or an appellate court’s disposition of petitioner’s direct appeal. As such, the court did not address whether Greer’s claims were also barred by Knaffla or reach the merits of Greer’s claims. The court also rejected Greer's claim that the district court's 2021 order vacating his second-degree murder conviction provided him an additional two years within which to bring a petition for postconviction relief. View "Greer v. State of Minnesota" on Justia Law

In 2020, Jaye William Snyder was charged with third- and fourth-degree criminal sexual conduct following an assault on an impaired victim. Snyder was convicted of third-degree criminal sexual conduct and was given a 140-month prison sentence. Due to a previous conviction of the same offense in 2016, he was also placed on lifetime conditional release after his prison term, as mandated by Minnesota Statutes § 609.3455, subdivision 7(b). Snyder appealed, arguing that the lifetime conditional release made his offense punishable by life imprisonment, which should have required the State to charge him by indictment rather than a criminal complaint, as per Minnesota Rule of Criminal Procedure 17.01, subdivision 1. However, the Minnesota Supreme Court held that their precedent in State v. Ronquist, which limited the indictment requirement to offenses punishable by life imprisonment before a sentencing enhancement is applied, remained good law and applied to Snyder's case. The court held that a lifetime conditional release did not invoke the indictment requirement of Rule 17.01, subdivision 1, and affirmed the decision of the lower court. View "State of Minnesota vs. Snyder" on Justia Law

In the case of Elsa E. Segura, the Minnesota Supreme Court examined whether the State presented sufficient evidence to sustain Segura's convictions for first-degree premeditated murder and attempted first-degree premeditated murder, under an aiding-and-abetting theory of criminal liability. The court also reviewed whether Segura was entitled to a new trial based on alleged prosecutorial misconduct and erroneous jury instructions.The State of Minnesota accused Segura of aiding and abetting in the kidnap and murder of Monique Baugh and the attempted murder of Baugh's boyfriend, J.M.-M., by luring Baugh to a fake house showing, where the principal perpetrators kidnapped her. Segura admitted to scheduling the house showing, but claimed she thought she was aiding in a drug business, not a kidnap-murder scheme.The Supreme Court found that although there was sufficient evidence to sustain Segura's convictions for kidnapping to commit great bodily harm or terrorize and felony murder while committing a kidnapping, there was insufficient evidence to sustain her convictions for first-degree premeditated murder and attempted first-degree premeditated murder. The court concluded that the jury instructions materially misstated the law and were not harmless beyond a reasonable doubt. Therefore, the court reversed Segura's convictions for kidnapping and felony murder and remanded the case for further proceedings consistent with its opinion. View "State vs. Segura" on Justia Law

In this case, the Supreme Court of Minnesota was tasked to interpret the statutory definition of a "dangerous weapon" as used in the case of Ayyoob Dawood Abdus-Salam, who was charged with two counts of second-degree riot for his alleged organization of two intersection "takeovers." During these events, several vehicles and large groups of pedestrians intentionally blocked off predetermined urban intersections, allowing drivers to perform dangerous stunts while crowds watched and filmed.The Supreme Court of Minnesota held that the term "likely" as used in the manner-of-use definition for "dangerous weapon" under Minn. Stat. § 609.02, subd. 6 (2022), is unambiguous and means "probable or reasonably expected." Furthermore, the court found that the district court erred when it dismissed two second-degree riot charges against Abdus-Salam for lack of probable cause, as sufficient facts in the record precluded granting a motion for a judgment of acquittal if proved at trial. The Supreme Court thus affirmed the decision of the court of appeals, ruling that because a reasonable jury could conclude from the facts alleged by the State that the vehicles used in the "takeovers" were dangerous weapons, the charges should not have been dismissed. View "State vs. Abdus-Salam" on Justia Law

In the case before the Supreme Court of Minnesota, the appellant, Larry Jonnell Gilbert, was convicted of possession of a firearm by an ineligible person. Gilbert then sought postconviction relief, alleging that the State's DNA expert gave false testimony at trial. The district court granted Gilbert a new trial without explicitly addressing whether Gilbert's claim was procedurally barred under the rule from State v. Knaffla, which states that all matters raised in a direct appeal and all claims known but not raised, will not be considered upon a subsequent petition for postconviction relief. The state appealed this decision and the court of appeals reversed it.The Supreme Court of Minnesota held that a district court abuses its discretion by granting a petition for postconviction relief without explicitly determining whether the claim is procedurally barred and offering a sufficient explanation to support a determination that the claim is not procedurally barred. Applying this to the facts of the case, the Supreme Court of Minnesota found that the district court abused its discretion by not explicitly determining whether Gilbert's claim was procedurally barred under Knaffla before granting postconviction relief. Therefore, the court affirmed the decision of the court of appeals, but on different grounds.Regarding the merits of Gilbert's claim about alleged false expert testimony, the court expressed no opinion, as it determined that Gilbert's postconviction claim was procedurally barred under Knaffla. View "Gilbert vs. State" on Justia Law

In Minnesota, a man convicted of taking pornographic photographs of a child was ordered by a district court to pay restitution for therapy costs and lost wages incurred by the child's mother. The appellant argued that the mother, as a secondary victim, was only eligible for restitution for losses suffered directly by the child. The State contended that under Minnesota Statutes section 611A.01, family members of the direct victim are part of a singular class of victims because when a child suffers, their parents suffer as well. The Minnesota Supreme Court agreed with the State's argument and affirmed the lower court's decision. It held that Minnesota Statutes section 611A.01(b) creates a singular class of victims that includes the direct victims of a crime and, if the direct victim is a minor, those family members of the minor who incur a personal loss or harm as a direct result of the crime. View "State of Minnesota vs. Allison" on Justia Law

In a case heard by the Supreme Court of Minnesota, the defendant, Christian Portillo, was charged with two counts of second-degree criminal sexual conduct. During the trial, the prosecutor elicited testimony from the State’s witnesses regarding evidence that the district court had previously ruled as inadmissible. The defendant's motion for a mistrial was denied by the district court. During the closing-argument rebuttal, the prosecutor told the jury that the defendant no longer held the presumption of innocence based on the evidence presented during the trial. The defendant did not object to this statement. The jury found the defendant guilty of one count of second-degree criminal sexual conduct.The defendant appealed, arguing that he was denied a fair trial due to prosecutorial errors committed by the State. The court of appeals affirmed the district court's decision, concluding that the prosecutor's misstatement of the law did not affect the defendant's substantial rights.Upon review, the Supreme Court of Minnesota reversed the decision of the court of appeals. The Supreme Court found that the prosecutor’s misstatement of the law during the closing-argument rebuttal was a plain error that affected the defendant’s substantial rights. The court held that the defendant is entitled to a new trial as the error must be addressed to ensure the fairness and integrity of the judicial proceedings. View "State of Minnesota vs. Portillo" on Justia Law

The Supreme Court affirmed Defendant's conviction for first-degree felony murder but reversed and vacated his conviction for second-degree murder, holding that it was error to convict Defendant of first-degree murder as well as the lesser-included offense of second-degree murder.After a jury trial, Defendant was found guilty of both first-degree felony murder and second-degree intentional murder and sentenced to life in prison with the possibility of release after thirty years. The Supreme Court affirmed in part and reversed in part, holding (1) the district court did not abuse its discretion by prohibiting Defendant from asserting his entrapment defense at trial and denying his request for jury instructions on the lesser-included offenses; (2) the evidence was sufficient to support the jury's guilty verdicts; but (3) the district court erred by entering convictions for both first-degree felony murder and second-degree intentional murder after the jury returned the guilty verdicts. View "State v. Cruz" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree intentional felony murder while committing burglary, holding that the State presented sufficient evidence to sustain Defendant's conviction.After a jury trial, Defendant was found guilty of three counts, including first-degree intentional felony murder while committing burglary. The trial court imposed a life sentence with eligibility for release after thirty years. Defendant appealed, arguing that the State presented insufficient evidence to prove his intent to kill. The Supreme Court affirmed, holding that the circumstantial evidence presented by the State was sufficient to support Defendant's conviction for first-degree intentional felony murder. View "State v. Colgrove" on Justia Law