Justia Minnesota Supreme Court Opinion Summaries

In this case, the appellant was convicted in 2005 of first-degree felony murder (kidnapping) in connection with the death of Robert Berry, Jr. The prosecution argued that he either caused Berry’s death or aided others with the intent to do so, relying on Minnesota’s statutes governing principal and aiding-and-abetting liability. The trial included evidence that the appellant participated in the events leading to Berry’s death, but it was unclear who inflicted the fatal wounds. The jury found the appellant guilty of first-degree felony murder based on kidnapping and acquitted him of other charges. The district court entered judgment on the felony murder conviction and imposed a life sentence without release.After his conviction, the appellant’s direct appeal was rejected by the Minnesota Supreme Court, which concluded there was sufficient evidence to support his conviction, though it did not specifically address whether he caused or intended to cause the victim’s death. Multiple postconviction petitions were also denied. In 2023, the Minnesota Legislature changed the law, narrowing liability for aiding and abetting first-degree felony murder and creating a procedure for those previously convicted to seek relief. The appellant filed a preliminary application under this new law, asserting he did not cause or intentionally aid in causing the victim’s death. The Redwood County District Court summarily denied the application, reasoning that the issues had already been decided by the Supreme Court in the appellant’s direct appeal.The Minnesota Supreme Court held that the district court abused its discretion in summarily denying the application because the prior decision did not resolve whether the appellant caused or aided with intent to cause the death. The court clarified that summary denial for previously decided issues is distinct from denial based on lack of reasonable probability. The court reversed the district court’s order and remanded for a determination of whether there is a reasonable probability that the appellant is entitled to relief under the new standard. The appellant’s other constitutional and procedural claims were rejected. View "Crow vs. State of Minnesota" on Justia Law

After a fatal shooting in a shared Minneapolis apartment, the defendant was charged with first-degree murder while committing domestic abuse with a past pattern of domestic abuse, as well as being a prohibited person in possession of a firearm. The defendant and the victim had been in a relationship and lived together; on the day of the incident, the victim had communicated to others her intention to end their relationship. Later that day, following an argument, the defendant called 911 twice to report a shooting, providing inconsistent information about his location. When police arrived at the apartment, they found the victim dead from a gunshot wound. At trial, the State presented evidence of the defendant’s prior abusive conduct toward several other romantic partners, as well as expert testimony on the dynamics of domestic violence.The Hennepin County District Court conducted the jury trial. During jury selection, the State used a peremptory strike on the only remaining Black venire member, prompting a Batson challenge by the defense, which was denied. The district court allowed the State’s domestic violence expert testimony, over defense objections. The jury found the defendant guilty on all counts, and the district court entered convictions for first-degree murder and firearm possession, sentencing the defendant to life with the possibility of release after 30 years.On direct appeal to the Minnesota Supreme Court, the defendant raised four main issues: the denial of his Batson challenge, the admission of domestic violence expert testimony, alleged prosecutorial misconduct during closing arguments, and the absence of a specific-unanimity jury instruction regarding the domestic abuse element. The Minnesota Supreme Court held that the district court did not clearly err in denying the Batson challenge, did not abuse its discretion in admitting the expert testimony, and that the prosecutor’s statements did not constitute misconduct. Furthermore, it found that any instructional error did not affect the defendant’s substantial rights. The court affirmed the convictions. View "State of Minnesota vs. Brown" on Justia Law

A two-year-old child, T.B., was found dead in an apartment in Mankato, Minnesota, with evidence of physical and sexual assault. At the time of the incident, the child’s mother and her boyfriend, L.Y., left the apartment around midnight to purchase a car, leaving T.B., his sister, and Lee Wayne Young, Jr. (then 16 years old) at home. Later that day, T.B. was discovered unresponsive in his bed. Forensic evidence indicated T.B. died from multiple traumatic injuries, with signs of sexual assault and the presence of semen and DNA linked to Young. There was also a small amount of methamphetamine in T.B.’s system, but it was not the cause of death.After an investigation, Young was indicted on multiple counts including first-degree murder. At trial in the Blue Earth County District Court, Young presented an alternative perpetrator defense, alleging that L.Y. was responsible for T.B.’s death. The district court allowed this defense but excluded certain evidence Young sought to introduce, such as L.Y.’s internet search history, prior methamphetamine convictions, and a recorded statement to police. The court also excluded a portion of a squad car video and a learned treatise on confirmation bias. Young was convicted of first-degree murder and other charges by a jury.Young appealed directly to the Minnesota Supreme Court and also filed a postconviction petition, which the district court denied. The Minnesota Supreme Court consolidated both appeals. The court reviewed each of Young’s evidentiary challenges and the denial of postconviction relief. It held that the district court had not abused its discretion in any of its evidentiary rulings, found any possible error in excluding a learned treatise was harmless beyond a reasonable doubt, and concluded that the admission of undisclosed expert opinion testimony did not affect Young’s substantial rights. The cumulative effect of any errors did not deny Young a fair trial. The Minnesota Supreme Court affirmed the conviction and denial of postconviction relief. View "State of Minnesota vs. Young" on Justia Law

The case involves the conviction of an individual for first-degree premeditated murder following a drive-by shooting. The defendant, who was engaged in drug sales, accused the victim of stealing money and drugs from his apartment. Tensions escalated after the theft, with the defendant expressing a desire to have the victim killed. On the night of the murder, evidence—including surveillance footage, forensic analysis of bullet casings, and testimony—connected the defendant and an associate to the crime. The defendant fled the state but made incriminating statements before and after his arrest.A Hennepin County grand jury indicted the defendant on two counts of first-degree murder. The case proceeded to trial in Hennepin County District Court. During the proceedings, the court made three key rulings: it excluded hearsay evidence from a co-defendant’s cellmate under Rule 804 because the proponent had not shown the co-defendant was legally unavailable; it excluded evidence of Facebook messages between the victim and a third party, finding their probative value was outweighed by the risk of confusing the jury; and it denied the defendant’s motion for mistrial after a witness referenced an alleged sexual relationship between the defendant and a minor, instead issuing a curative instruction to the jury. The jury convicted the defendant on both counts, and the district court imposed a life sentence without the possibility of release.The Minnesota Supreme Court reviewed the case and affirmed the district court’s decisions. It held that the exclusion of the cellmate’s testimony was not an abuse of discretion because the defendant failed to establish the co-defendant’s unavailability. The exclusion of the Facebook evidence was affirmed as the risk of jury confusion outweighed any minimal probative value. The denial of the mistrial motion was also upheld, as there was no reasonable probability the outcome would have been different but for the contested testimony. View "State of Minnesota vs. Johnson" on Justia Law

An applicant for a public sector web developer position was initially offered employment by a state agency, Minnesota IT Services (MNIT), contingent upon a background check. The background investigation revealed the applicant’s 2017 conviction for possession of child pornography. In compliance with the Criminal Offenders Rehabilitation Act (CORA), MNIT determined the conviction directly related to the position and requested evidence of rehabilitation and present fitness from the applicant. The applicant submitted documentation, including an early discharge from probation, evidence of law-abiding behavior since release, a description of the offense’s circumstances, and several reference letters. Despite this, MNIT concluded the conviction disqualified the applicant from employment and imposed a ten-year bar on reapplying.The applicant challenged the disqualification through the Minnesota Administrative Procedure Act. After both parties sought summary disposition, an administrative law judge (ALJ) found the applicant had provided sufficient evidence of rehabilitation and recommended the disqualification be rescinded. The Commissioner of MNIT, however, rejected the ALJ’s legal conclusions and recommendation, and remanded the matter for a contested case hearing. Following a related Minnesota Supreme Court decision clarifying that agencies lacked authority to remand to ALJs under the relevant administrative statute, the ALJ determined he lacked jurisdiction to proceed. The Commissioner then issued a final order affirming the disqualification, allowing the applicant to reapply in 2027. The applicant appealed to the Minnesota Court of Appeals, which reversed the Commissioner’s decision, holding that MNIT lacked discretion to disqualify the applicant after competent evidence of rehabilitation was provided.The Minnesota Supreme Court reviewed the case. It held that the ALJ’s recommendation was not the final decision, as the Commissioner timely rejected it within statutory limits. On the substantive question, the Court found that a public employer retains discretion under CORA to determine whether an applicant has demonstrated sufficient rehabilitation and present fitness after the applicant submits competent evidence. The Court affirmed in part, reversed in part, and remanded for further proceedings. View "McNitt vs. Minnesota IT Services" on Justia Law

A police officer attempted to stop a driver on a rural Minnesota highway shortly after midnight because he believed the van lacked a visible rear license plate or temporary registration. The driver, instead of stopping, turned on his hazard lights and continued driving for several miles with the officer in pursuit, ignoring repeated commands to stop. The pursuit ended only after additional officers joined and the driver stopped at a protest encampment. After his arrest, officers determined the van did have valid temporary registration, but the driver was charged with felony fleeing a peace officer in a motor vehicle.At trial in the District Court, the driver moved to suppress evidence of his flight, arguing that the initial traffic stop was unconstitutional and that the subsequent evidence of fleeing was “fruit of the poisonous tree.” The District Court denied the motion, finding the officer had an objective reason for the stop. A jury convicted the driver. On appeal, the Minnesota Court of Appeals held the traffic stop was unconstitutional but affirmed the conviction, concluding that the evidence of flight was admissible under existing law.The Minnesota Supreme Court reviewed whether, under the Minnesota Constitution, evidence of a defendant’s new crime—here, vehicular flight—committed in response to an unconstitutional seizure must be suppressed. The court held that courts should apply the four-factor attenuation test from State v. Warndahl to determine if such evidence is the fruit of the poisonous tree. Applying this test, the court found that the driver’s flight was an intervening act of free will that attenuated the connection to the unconstitutional stop, and thus, the exclusionary rule did not require suppression. The Supreme Court affirmed the decision of the Court of Appeals. View "State of Minnesota vs. Engel" on Justia Law

A police officer in Thief River Falls, Minnesota, attempted to stop Nicholas Engel’s van late at night because he did not see a rear license plate or visible temporary registration. Rather than pull over, Engel turned on his hazard lights and continued driving for several miles, despite the officer’s emergency lights, siren, and repeated verbal commands to stop. Engel eventually stopped only after additional officers arrived and boxed in his vehicle near a protest camp. He was arrested and charged with felony fleeing a peace officer in a motor vehicle.The Thief River Falls District Court denied Engel’s motion to suppress evidence of his vehicular flight, concluding the officer had an objective reason to initiate the stop. After a jury convicted Engel, the Minnesota Court of Appeals affirmed, though all panel members agreed the traffic stop was unconstitutional because the officer lacked reasonable, articulable suspicion for the stop. The majority held that suppression of evidence of Engel’s flight was not warranted, while the dissent argued that the flight was fruit of the unconstitutional seizure and should be suppressed.The Supreme Court of Minnesota reviewed the case to determine whether evidence of Engel’s vehicular flight, which constituted a new crime in response to an unconstitutional stop, must be suppressed under the exclusionary rule of the Minnesota Constitution. The court held that when a suspect commits a new crime after law enforcement commits a constitutional violation, courts must apply the four-factor attenuation test from State v. Warndahl to determine whether the evidence of the new crime is fruit of the poisonous tree. Applying this test, the court found Engel’s flight to be an intervening act not sufficiently connected to the unconstitutional stop to warrant suppression. The court affirmed the decision of the Court of Appeals. View "State of Minnesota vs. Engel" on Justia Law

The case involved the death of Sara Hagfors on April 9, 2021. Her husband, Keith D. Hagfors, sought to bring a wrongful death action on behalf of her next of kin. Eighteen days before the statute of limitations expired, he petitioned to be appointed as trustee, as required by Minnesota law. However, before receiving the appointment, he served a summons and complaint on several healthcare defendants, alleging wrongful death. He was officially appointed trustee five days later and then filed the complaint. He did not re-serve the summons after his appointment but before the limitations period expired.The Ramsey County District Court dismissed the complaint for lack of subject matter jurisdiction and failure to state a claim, concluding that Hagfors had not validly commenced the wrongful death action because he was not appointed trustee at the time of service. Hagfors attempted to have his appointment as trustee backdated via a nunc pro tunc order in the separate trustee proceeding, but the district court denied reconsideration, and Hagfors voluntarily dismissed any appeal related to that issue. The Minnesota Court of Appeals affirmed the district court, holding that serving the complaint before being appointed trustee rendered the action a nullity, and as an error-correcting court, it was bound by Minnesota Supreme Court precedent.The Minnesota Supreme Court reviewed the case to determine whether appointment as trustee is a condition precedent to commencing a wrongful death action under Minn. Stat. § 573.02. The court held that appointment as trustee is indeed a condition precedent to commencing such an action. Any attempt to begin a wrongful death action without being appointed trustee is a legal nullity, and subsequent appointment does not validate the original filing. The decision of the court of appeals was affirmed. View "Hagfors vs. Fairview Health Services" on Justia Law

In this case, the petitioner was convicted of second-degree unintentional felony murder, attempted second-degree murder, and first-degree aggravated robbery in connection with a 2013 incident in Minneapolis. The petitioner and his accomplice planned to commit robberies, ultimately attempting to rob several individuals. During the course of these events, the petitioner handed a pistol to his accomplice, who then used it to fatally shoot one of the victims. The petitioner subsequently pleaded guilty to the charges based on an aiding-and-abetting theory of liability.Following legislative changes in 2023 and 2024 that narrowed the scope of criminal liability for aiding and abetting second-degree felony murder, the petitioner sought to vacate his conviction under a new statutory procedure. He argued that he was not a “major participant” in the underlying felony and did not act with “extreme indifference to human life.” The Hennepin County District Court denied the petition without holding an evidentiary hearing, finding that the petitioner’s actions met both statutory criteria. The Minnesota Court of Appeals affirmed, applying a reasonable-probability standard that defined “reasonable probability” as “a probability sufficient to undermine confidence in the outcome of the case,” and concluded that the petitioner’s entitlement to relief was refuted by the record.The Supreme Court of Minnesota reviewed the case and clarified that the “reasonable probability” standard it previously articulated in State v. Zielinski, 32 N.W.3d 847 (Minn. 2026), applies to denials of petitions under this statutory scheme. The court held that the standard used by the court of appeals differed materially from the Zielinski standard. Consequently, the Supreme Court reversed the decision of the court of appeals and remanded the case for further proceedings using the correct legal standard. View "Grant vs. State of Minnesota" on Justia Law

A nonprofit organization and two registered Minnesota voters challenged the state’s requirement that absentee voters obtain a witness certification in order to cast an absentee ballot. The organization assists its members with the absentee voting process. The plaintiffs argued that the requirement violates two federal laws: the Voting Rights Act, by conditioning the right to vote on a “voucher” from a witness, and the Civil Rights Act’s Materiality Provision, by potentially denying the right to vote based on errors or omissions in witness certifications that are not material to determining voter eligibility.The case began in district court, where the Secretary of State moved to dismiss, arguing the plaintiffs lacked standing and failed to state claims. The district court denied the motion, finding the organization had standing. It ruled that the plaintiffs stated a claim under the Voting Rights Act for unregistered voters and under the Civil Rights Act for registered voters. The Secretary then sought discretionary review. The Minnesota Court of Appeals concluded the organization had standing but held that the witness certification requirement did not violate either federal law, reversing the district court and remanding with instructions to dismiss the case.The Minnesota Supreme Court reviewed the appeal. It held that the witness certification does not violate the Voting Rights Act for unregistered voters because it does not require proving eligibility by the voucher of another; the witness merely attests to the presentation of residency documentation, not personal knowledge of the voter’s qualifications. The court also held that, as to registered voters, the witness certification is not a paper relating to an “act requisite to voting” under the Civil Rights Act’s Materiality Provision, as it does not pertain to a determination of voter eligibility. The Minnesota Supreme Court affirmed the decision of the Court of Appeals, concluding that the plaintiffs failed to state claims under either federal law. View "Minnesota Alliance for Retired Americans Educational Fund vs. Simon" on Justia Law