Justia Criminal Law Opinion Summaries

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

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of one count of possession of a firearm by an ineligible person under Minn. Stat. 609.165, subd. 1b(a), holding that a dissembled and incomplete shotgun can meet the plain language definition of a firearm under section 609.165, subd. 1b(a).Law enforcement officers discovered a disassembled twenty-gauge shotgun in Defendant's backpack, and a forensic scientist used a bolt and washer from a similar firearm to assembly and successfully fire the shotgun at issue. Defendant was found guilty of one count of possession of a firearm by an ineligible person. The court of appeals affirmed. The Supreme Court affirmed, holding that the evidence was sufficient for the jury to reach the commonsense verdict that it did. View "State v. Stone" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court granting Defendant's motion to suppress evidence found during a search of his vehicle, holding that the odor of marijuana emanating from a vehicle, alone, is insufficient to create the requisite probable cause to search a vehicle under the automobile exception to the warrant requirement.After a traffic stop and subsequent search of his vehicle Defendant was convicting of possession of methamphetamine paraphernalia in the presence of a minor and fifth-degree possession of a controlled substance. Defendant moved to suppress the evidence, arguing that the odor of marijuana, alone, is insufficient to create the requisite probable cause to search a vehicle under the automobile exception to the warrant requirement. The district court granted the motion and dismissed the complaint. The court of appeals affirmed. The Supreme Court affirmed, holding that evidence of medium-strength odor of marijuana, on its own, is insufficient to establish a fair probability that the search would yield evidence of criminally-illegal conduct or drug-related contraband. View "State v. Torgerson" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of falsely reporting a crime to a police officer, holding that the evidence was sufficient to support the conviction and that venue was proper in Waseca County.Defendant's conviction was based on her false report to police that the father of her child had abused their child. Because Defendant was in Blue Earth County when she made the report she argued on appeal that venue was improper in Waseca County and that the evidence was insufficient to sustain her conviction. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the State met its burden to show venue based on the location of the officer receiving the false report; and (2) the evidence was sufficient to support Defendant's conviction. View "State v. Johnson" on Justia Law