Justia Minnesota Supreme Court Opinion Summaries

The Supreme Court of Minnesota reviewed a case in which Robert John Kaiser had been convicted of second-degree felony murder for the death of his infant son. Kaiser sought postconviction relief, arguing that two expert witnesses for the State had presented false evidence at his trial. The district court granted a new trial, determining that the expert testimony at issue was indeed false and that the jury might have reached a different conclusion without it. The State appealed this decision, arguing that the district court abused its discretion in ordering a new trial.The Supreme Court of Minnesota upheld the lower court's decision, stating that the district court had not abused its discretion. It held that the Larrison test, which is used to determine the legitimacy of claims of witness recantation or false trial testimony, was the appropriate legal standard for this case. The court found that the expert testimony presented at Kaiser's trial was factual and false, thus meeting the requirements of the Larrison test. The court further found that the jury might have returned a different verdict without the false testimony. Therefore, the Supreme Court of Minnesota affirmed the decision of the lower courts to grant Kaiser a new trial. View "Kaiser vs. State" on Justia Law

In the case before the Supreme Court of Minnesota, clerical and technical employees of the Anoka County Sheriff's Office, represented by the Law Enforcement Labor Services, Inc. (the Union), submitted a petition to the Bureau of Mediation Services (the Bureau) to determine an appropriate collective bargaining unit. The County opposed the unit, proposing a broader, county-wide unit. The Bureau found the County's unit to be the more appropriate choice. The Union appealed this decision, arguing that the Bureau had made numerous errors of law.The Supreme Court held that the Bureau did not improperly compare the Union's proposed unit to that of the County's. The Court determined that under the Public Employment Labor Relations Act (PELRA), overfragmentation is one of the "other relevant factors" that the Bureau is allowed to consider when analyzing statutory factors for a unit determination. However, the Court found that the Bureau gave priority and effectively controlling weight to its four-unit preference and the related overfragmentation concerns over the specific factors listed in PELRA. This was deemed to be an error of law.Consequently, the Court reversed the decision of the Bureau and remanded for further proceedings, instructing that a bargaining unit determination must now be made by the Bureau giving appropriate weight and consideration to the statutory factors in PELRA. View "Anoka County, Minnesota vs. Law Enforcement Labor Services, Inc." on Justia Law

In Minnesota, a defendant, Rebecca Julie Malecha, was arrested on a warrant that had been quashed but was still appearing as active in law enforcement databases due to a clerical error by court administration. During the arrest, police discovered controlled substances on Malecha's person and charged her with four controlled substance crimes. Malecha moved to dismiss the charges, arguing the search was unconstitutional due to the quashed warrant. The district court granted her motion, based on the violation of Article I, Section 10, of the Minnesota Constitution, but the court of appeals reversed this decision.The Minnesota Supreme Court reversed the court of appeals, holding that the good-faith exception to the exclusionary rule does not apply to evidence obtained during a search on a quashed warrant that appears active to law enforcement because of a clerical error by court administration. The court reasoned that applying the exclusionary rule would serve to deter unlawful government conduct generally, not just police misconduct. The court emphasized that the benefits of excluding illegally obtained evidence outweighed the costs in this case, particularly in situations where the constitutional violation stemmed from a court clerical error. Therefore, the charges against Malecha were dismissed. View "State of Minnesota vs. Malecha" on Justia Law

The State of Minnesota Supreme Court affirmed the decision of the Court of Appeals that the District Court did not abuse its discretion when it ordered an upward durational sentencing departure for third-degree criminal sexual conduct against a physically helpless person, in violation of Minnesota Statutes section 609.344, subdivision 1(d) (2020), when the offense occurred in the victim’s zone of privacy.The appellant, Curtis Lablanche Vanengen, was found guilty by the jury of third-degree criminal sexual conduct against a physically helpless person. The offense took place in the victim’s bedroom, which the jury determined as the victim’s zone of privacy. The district court sentenced Vanengen to 120 months in prison, a 29-month upward durational departure from the top of the presumptive sentencing guidelines range.Vanengen appealed, arguing that the location of the offense in the victim’s bedroom did not make it “significantly more serious” than the “typical” criminal sexual conduct offense against a physically helpless person who is asleep. The court of appeals and the Supreme Court disagreed, stating that the victim was entitled to safety and security in her own home, and the violation of this security by committing the offense in her private zone justified the upward departure. The Supreme Court concluded that the zone-of-privacy aggravating factor was a legally permissible reason for an upward departure in this type of case and was factually supported in the record. The court affirmed the decision of the court of appeals. View "State of Minnesota vs. Vanengen" on Justia Law

The case involves a juvenile, D.J.F.-D., who was charged with a gross misdemeanor offense. The juvenile court found D.J.F.-D. incompetent to proceed and suspended the proceedings against him for one year. During this period, the State filed its first notice of intention to prosecute D.J.F.-D., extending the suspension for another year. Subsequently, the juvenile court made two additional findings of incompetency. Before the extended suspension period expired, D.J.F.-D. moved to dismiss the proceedings, arguing that Rule 20.01, subdivision 7(A) of the Minnesota Rules of Juvenile Delinquency Procedure allows the State to file only one notice of intention to prosecute. The juvenile court denied his motion, which was affirmed by the court of appeals in a divided opinion.The Supreme Court of Minnesota was asked to determine whether Rule 20.01, subdivision 7(A), allows the State to file more than one notice of intention to prosecute a child found incompetent to proceed. The court concluded that the rule permits the State to file more than one notice of intention to prosecute, provided that the juvenile court continues to make findings of incompetency. This decision allows the suspension of delinquency proceedings to be extended until the child either regains competency or ages out of juvenile jurisdiction. The court affirmed the decision of the court of appeals. View "In the Matter of the Welfare D.J.F.-D." on Justia Law

This case revolves around the appellant, Sheldon James Thompson, who was convicted for the brutal murders of his girlfriend, her 20-month-old son, and her unborn child. Thompson was convicted by a jury for eight offenses, including first-degree premeditated murder for each victim. The jury's decision was based on the prosecution's argument, which included statements about Thompson's motive and activities before, during, and after the murders. Thompson appealed his conviction, asserting that the prosecutor committed unobjected-to misconduct during the closing argument, which affected his substantial rights. He also contended that the court should order a new trial as prosecutors continued to make speculative statements during closing arguments.The Minnesota Supreme Court, however, affirmed the conviction. The court held that the State had met its burden to show that Thompson’s substantial rights were not affected by any alleged plain error in the prosecutor’s closing argument. The court also determined that Thompson had failed to establish that speculative statements were a widespread form of prosecutorial misconduct; thus, a prophylactic reversal was not warranted. This conclusion was based on the strength of the evidence against Thompson, the limited extent of the alleged misconduct, and the opportunity Thompson had to rebut any improper remarks. View "State of Minnesota vs. Thompson" on Justia Law

In Minnesota, the defendant, Otha Eric Townsend, who was convicted of first-degree murder and attempted second-degree murder, appealed the denial of his third motion to correct his sentence. The two crimes were tried separately, and Townsend was first sentenced to life in prison with the possibility of release after 30 years for the murder conviction. Months later, he was sentenced to serve 72 months in prison consecutively to his life sentence for the attempted murder conviction. Townsend argued that custody credit should be applied to the first of his two consecutive sentences. However, the Minnesota Supreme Court held that the law of the case doctrine barred Townsend's appeal. The court stated that they had already decided in previous rulings that Townsend was not entitled to custody credit on his life sentence and that the district court properly applied custody credit to Townsend’s sentence for attempted second-degree murder. Therefore, the court affirmed the district court's decision and denied Townsend's motion to correct his sentence. View "Townsend vs. State" on Justia Law

The Minnesota Supreme Court affirmed the convictions of Gregory Paul Ulrich for first-degree premeditated murder, attempted first-degree premeditated murder, and discharge of an explosive or incendiary device. Ulrich had targeted the Allina Health clinic in Wright County, where he had been treated, because he was dissatisfied with his medical care and blamed the clinic for his chronic pain. He had recorded videos threatening the clinic, purchased a gun and supplies for making pipe bombs, and then carried out an attack at the clinic, shooting several people and detonating three pipe bombs. On appeal, Ulrich argued that the lower court had abused its discretion by denying his motions to strike a juror for cause and to change the venue, and that the evidence was insufficient to support his convictions. The Supreme Court ruled that the lower court had not abused its discretion because the juror had not expressed actual bias requiring either rehabilitation or removal, and because Ulrich had not renewed his motion to change the venue after voir dire, thereby forfeiting his right to contest the denial of his motion. The Supreme Court also ruled that the evidence was sufficient to support the convictions because it supported a reasonable inference that Ulrich had planned the attack and believed that it would cause the victims' deaths. View "State v. Ulrich" on Justia Law

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