Justia Criminal Law Opinion Summaries

In this interlocutory appeal, the Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court granting Defendant's motion to suppress statements recorded on a body-worn camera, holding that the district court did not abuse its discretion in determining that the statements should be suppressed.In response to a domestic disturbance 911 call law enforcement officers found A.H. locked out of her apartment while Defendant was inside, and A.H. told the officers that Defendant had assaulted her both in the present and in the past. These statements were recorded by an officer's body-worn camera. Defendant was subsequently charged with one count of misdemeanor domestic assault. The district court granted Defendant's motion to suppress the body-worn camera recording on the grounds that their admission would violate Defendant's constitutional right to confrontation. The court of appeals affirmed. The Supreme Court affirmed, holding that the district court (1) did not abuse its discretion in determining that A.H.'s statements did not qualify as excited utterances under Minn. R. Evid. 802(2); and (2) properly suppressed the statements as inadmissible hearsay. View "State v. Tapper" on Justia Law

The Supreme Court reversed Defendant's conviction of first-degree premeditated murder and second-degree intentional murder following a jury trial, holding that the district court erred in entering a conviction for the lesser-included offense of second-degree intentional murder.After the trial, the district court entered judgment of convictions for both first-degree and second-degree murder but only imposed a sentence for the first-degree murder conviction. The Supreme Court held (1) the evidence was sufficient to prove the element of premeditation for the first-degree murder offense; (2) assuming, without deciding, that the district court erred by failing to identify a certain individual as an accomplice, the failure did not affect Defendant's substantial rights; (3) the district court did not commit any other reversible error in managing the trial and the jury instructions; and (4) the entry of a judgment of conviction for the second-degree intentional murder offense violated Minn. Stat. 609.04, subd. 1. View "State v. Gilleylen" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Appellant's second petition for postconviction relief, holding that Appellant was not entitled to relief on his allegations of error.After a jury trial, Appellant was convicted of first-degree premeditated murder and sentenced to life imprisonment without the possibility of release. The Supreme Court affirmed the conviction and the denial of Appellant's initial petition for postconviction relief. Thereafter, Appellant filed another postconviction petition. The postconviction court summarily denied the petition and denied Appellant's motion to compel discovery. On appeal, Appellant argued, among other things, that his appellate counsel provided ineffective assistance. The Supreme Court affirmed, holding that Appellant was conclusively entitled to no relief. View "Allwine v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Appellant's motion to correct his sentence under Minn. R. Crim. P. 27.03, subd. 9, holding that Appellant's sentence of life imprisonment was mandated by Minn. Stat. 609.185(1).Appellant pleaded guilty to an amended count for first-degree intentional murder while committing a kidnapping and second-degree intentional murder. The district court ultimately convicted Appellant of first-degree premeditated murder and dismissed the second-degree murder count. In this action arising from Defendant's third motion to correct his sentence Defendant argued that the district court violated his due process right by sentencing him to a longer sentence than that recommended in the sentencing worksheet completed for the charge of second-degree murder. The district court concluded that the failure to file a sentencing worksheet for the charge of first-degree murder does not cause a defendant's sentence to be unauthorized or a defendant's due process rights to be violated. The Supreme Court affirmed, holding that there was no error. View "Johnson v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court granting Defendant's motion to dismiss Plaintiff's action brought under 42 U.S.C. 1983 alleging that Minnesota's continuing predatory-offender registration requirements violated his rights under the federal and state constitutions, holding that there was no error.More than a decade after he pleaded guilty to second-degree assault and was required to register as a predatory offender under Minn. Stat. 243.166, subd. 1b Plaintiff brought this action. The district court concluded that the statutory limitations period of six years under Minn. Stat. 541.05, subd. 1(5) barred Plaintiff's section 1983 claims and that the continuing-violation doctrine does not apply to predatory-offender registration requirements. The court of appeals affirmed. The Supreme Court affirmed, holding that the continuing-violation doctrine did not toll the statute of limitations for Plaintiff's claims. View "Franklin v. Evans" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of first-degree arson under Minn. Stat. 609.561, subd. 1, holding that the evidence provided at trial was sufficient to support Defendant's conviction.On appeal, Defendant argued that the word "unlawfully" in the first-degree arson statute created an element of the offense that the State must prove beyond a reasonable doubt and that the State failed establish all of the elements of his crime by failing to present evidence to show that the burning of his house was "unlawful." The court of appeals affirmed the conviction. The Supreme Court affirmed, holding (1) under section 609.561, the State must prove that a person set a fire in a manner not authorized by law as an element of first-degree arson; and (2) the trial court failed properly to instruct the jury, but there was no reasonable likelihood that the jury would have reached a different result had it been properly instructed that the State was required to prove that Defendant started the fire unlawfully. View "State v. Beganovic" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the judgment of the district court declaring Appellant eligible to submit a petition seeking compensation based on exoneration under Minnesota's Incarceration and Exoneration Remedies Act, Minn. Stat. 611.362 to 611.368, holding that Appellant was not eligible for compensation based on exoneration.At issue was whether Appellant had established, by a fair preponderance of the evidence, that she was exonerated within the meaning of Minn. Stat. 590.11. The district court concluded that Appellant was eligible for compensation based on a finding of exoneration. The court of appeals agreed that Appellant was "exonerated" but remanded for the district court to determine a separate issue. The Supreme Court reversed, holding that Appellant was not eligible for compensation based on exoneration. View "Back v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Appellant's petition for postconviction relief from his conviction for first-degree felony murder under an aiding and abetting theory of criminal liability, holding that Appellant's arguments did not entitle him to relief.In his petition for postconviction relief, Appellant claimed in part that he received ineffective assistance of trial counsel because counsel did not communicate an Alford plea deal to him. The district court denied the petition, concluding that Appellant failed to prove his claim by a preponderance of the evidence. The Supreme Court affirmed, holding that the evidence established beyond a reasonable doubt that Appellant committed first-degree felony murder under an aiding and abetting theory of criminal liability. View "State v. King" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of fifth-degree possession of a controlled substance, holding that the search of Defendant's purse was constitutional under the automobile exception to the Fourth Amendment's search warrant requirement.Defendant, a passenger in a vehicle searched by law enforcement without a warrant, removed her purse from the car as she got out, but an officer directed her to leave the purse on the car. The officer's ensuing search of the purse revealed a controlled substance. Defendant filed a motion to suppress, arguing that the automobile exception did not apply because the purse was an extension of her person, not a container within the car. The district court denied the motion. The court of appeals affirmed the denial, concluding that the warrantless search of Defendant's purse was constitutional. The Supreme Court affirmed, holding that (1) the purse was a container that was inside the car at the time probable cause arose; and (2) because the purse could have contained marijuana, the officer was permitted to search it under the automobile exception. View "State v. Barrow" on Justia Law

The Supreme Court affirmed the judgment of the district court summarily denying Appellant's second petition for postconviction relief as time-barred because Appellant's postconviction claim failed to satisfy the newly discovered evidence or the interests of justice exceptions, holding that the district court did not abuse its discretion.Defendant was convicted of premeditated first-degree murder following a jury trial. Defendant later brought this postconviction petition asserting that the State committed a Brady violation when it failed to disclose this exculpatory information before his trial. The district court summary denied the petition as time-barred. The Supreme Court affirmed, holding that because Defendant's claims did not satisfy the newly discovered evidence or the interests of justice exceptions the district court properly denied Defendant's second postconviction petition as untimely. View "Blanche v. State" on Justia Law