Justia Criminal Law Opinion Summaries

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

The Supreme Court affirmed Defendant's convictions of first-degree premeditated murder and attempted second-degree murder, holding that any error in the underlying proceedings was harmless.In its written findings of fact, the trial court made a finding related to Defendant's defense that was unsupported by the record concerning business closures at the beginning of the COVID-19 pandemic and used this finding as part of its assessment of Defendant's credibility. The Supreme Court affirmed, holding (1) the district court's pandemic-related finding did not require a new trial under any of the impartiality tests; and (2) the district court's failure to consider the lesser-included offense of second-degree unintentional felony murder in its deliberations was harmless. View "State v. Lopez" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the court of appeals in this criminal case and vacated both of Defendant's convictions for two marijuana-related fifth-degree controlled substance offenses, holding that the evidence was insufficient to support the convictions.One of Defendant's convictions was based on Defendant's alleged possession of approximately three pounds of plant material that the State asserted was marijuana, and the other conviction was based on Defendant's alleged possession with intent to sell one or more vaporizer cartridges filled with a liquid mixture containing THC. The court of appeals (1) reversed Defendant's conviction for possession of the plant material on the grounds that a 2019 amendment to the definition of marijuana in Minn. Stat. 152.01, subd. 9 explicitly excluded "hemp"; and (2) upheld Defendant's second conviction. The Supreme Court reversed in part, holding that the court of appeals (1) properly held that the State did not present sufficient evidence to prove that the plant material possessed by Defendant was marijuana as defined by the amended statute; but (2) erred in concluding that the State presented sufficient evidence to prove that the liquid mixture in the vaporizer cartridges was a prohibited schedule I controlled substance. View "State v. Loveless" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the restitution order issued by the district court in Defendant's criminal case, holding that Minn. Stat. 611A.045, subd. 3(a) imposes no burden on the State to prove a defendant's income, resources, and obligations.Defendant pleaded guilty to second-degree unintentional felony murder. As part of his sentence, the district court ordered him to pay $7,500 in restitution for the victim's funeral expenses. Defendant filed a motion to relieve his restitution obligation, arguing that under section 611A.045, subd.1(a)(2) a district court is required to consider the defendant's income, resources, and obligations. The district court denied the motion. The court of appeals affirmed, concluding that the State does not bear the burden of producing evidence of or proving a defendant's ability to pay restitution. The Supreme Court affirmed, holding that the State's statutory burden under Minn. Stat. 611A.045, subd.3(a) does not require the State to prove that the defendant is able to pay restitution based on his or her income, resources, and obligations. View "State v. Cloutier" on Justia Law