Articles Posted in Civil Rights

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The Supreme Court affirmed in part and reversed and remanded in part the postconviction court’s denial of Petitioner’s second petition for postconviction relief without holding an evidentiary hearing. Petitioner was found guilty of first-degree premeditated murder and sentenced to life in prison without the possibility of release. After his first postconviction petition was summarily denied, Petitioner filed his second postconviction petition, alleging the existence of sixteen pieces of newly discovered evidence. The postconviction court denied the second petition without holding an evidentiary hearing, concluding that the petition was untimely because the facts alleged in the petition did not satisfy the statutory newly-discovered-evidence exception. The Supreme Court reversed in part, holding (1) the postconviction court abused its discretion by making improper credibility determinations without holding an evidentiary hearing; and (2) the facts alleged in support of Petitioner’s remaining claims did not satisfy the newly-discovered-evidence or interests-of-justice exceptions to the two-year statute of limitations. View "Anderson v. State" on Justia Law

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The Supreme Court affirmed the postconviction court’s denial of Petitioner’s petition for postconviction relief, holding that the postconviction court did not abuse its discretion. Petitioner was found guilty of first-degree premeditated murder and first-degree felony murder. Petitioner was sentenced to life imprisonment without the possibility of release for the murder conviction. The Supreme Court affirmed. Petitioner later filed a petition for postconviction relief, alleging six grounds for postconviction relief. The postconviction court rejected the petition without holding an evidentiary hearing. The Supreme Court affirmed, holding that Petitioner’s claims were either procedurally barred or failed as a matter of law. View "Fox v. State" on Justia Law

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The limited right to counsel recognized in Friedman v. Commissioner of Public Safety, 473 N.W. 2d 828 (Minn. 1991), applies only to implied-consent cases. The district court in this case suppressed the results of a urine sample provided by Defendant at a jail after his arrest for driving while impaired (DWI) because the sheriff’s deputy, when asking Defendant if he would consent to urine testing, failed to read the implied-consent advisory that would have advised Defendant of his right to counsel. The court concluded that, by failing to read the advisory, the deputy failed to allow Defendant to vindicate his right to counsel prior to testing. The court of appeals reversed. The Supreme Court affirmed, holding (1) because the officer did not read the implied-consent advisory in this case, under Friedman, the limited right to counsel was not triggered; and (2) therefore, the district court erred in suppressing the urine test results on that ground. View "State v. Hunn" on Justia Law

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The Supreme Court reversed the decisions of the court of appeals and district court that Respondent’s due process rights were violated when he was read an inaccurate implied consent advisory after his arrest on suspicion of driving while impaired. Respondent refused to submit to either a urine or a blood test. Thereafter, the Commissioner of Public Safety revoked Respondent’s driver’s license for refusing to submit to a test. Relying on McDonnell v. Commissioner of Public Safety, 473 N.W.2d 848 (Minn. 1991), the district court rescinded the revocation after finding that the implied consent advisory violated Respondent’s due process rights because it incorrectly stated that refusal to submit to a urine test was a crime. The court of appeals affirmed on the basis that the threat of legally impossible criminal charges for refusal to submit to a urine test violated due process. The Supreme Court reversed, holding that because Respondent did not rely on the implied consent advisory to his detriment, and instead refused to submit to testing, no due process violation occurred under McDonnell. View "Johnson v. Commissioner of Public Safety" on Justia Law

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Appellant failed to establish that he was prejudiced by the implied consent advisory read to him after he was arrested on suspicion of driving while impaired, and therefore, Appellant was not entitled to a rescission of his license revocation under McDonnell v. Commissioner of Public Safety, 473 N.W.2d 848 (Minn. 1991). Appellant submitted to a blood test, and the test results showed an alcohol concentration above the legal limit. Appellant’s driver’s license was subsequently revoked. The district court sustained the revocation on the basis that Appellant voluntarily consented to the blood test. The Supreme Court affirmed, holding that Appellant was not entitled to a rescission of his license revocation under McDonnell because he did not even claim, much less establish, that he prejudicially relied on the implied consent advisory. View "Morehouse v. Commissioner of Public Safety" on Justia Law

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Law enforcement officers did not violate Defendant’s Fifth Amendment privilege against self-incrimination when, after Defendant invoked his privilege against self-incrimination, they later asked him if he was willing to sign a written consent to the taking of a DNA sample and explained to him why they sought the sample. Defendant was charged with possession of a firearm by an ineligible person and possession of a short-barreled shotgun. Defendant filed a motion to suppress DNA evidence and his admission that he had handled the shotgun, claiming that the officers conducted a second custodial interrogation after he had invoked his privilege against self-incrimination. The district court denied the motion. The Supreme Court affirmed, holding that the officers did not violate Defendant’s constitutional privilege against self-incrimination because, although Defendant’s statements that he had already handled the shotgun were incriminating testimonial communications, none of the officers’ actions were reasonably likely to elicit an incriminating testimonial communication. Therefore, a Miranda warning was not required. View "State v. Heinonen" on Justia Law

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Failing to register is a continuing crime that includes the entire range of dates on which Defendant failed to register in this case, and a jury was not required to find the date of Defendant’s current offense. Defendant was convicted of knowingly failing to register as a predatory offender. Under the Minnesota Sentencing Guidelines, prior felony sentences are used to calculate criminal history scores unless a period of fifteen years has elapsed between “the date of the current offense” and the expiration of the prior felony sentence (see Minn. Stat. 243.166). Defendant argued that “the date of the current offense” for his crime was the last day the offense occurred and that a jury must decide that date. The court of appeals concluded that “the date of the current offense,” which is a continuing offense, is the first day the offense occurs. The Supreme Court affirmed, holding (1) the district court did not err in including Defendant’s 1996 felony conviction in his criminal history score because fifteen years had not elapsed between the expiration of Defendant’s sentence for his 1996 conviction and the start of his current offense; and (2) Defendant’s sentence did not violate his Sixth Amendment right to a jury trial under Blakely v. Washington, 542 U.S. 296 (2004). View "State v. Washington" on Justia Law

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The warrantless search of Defendant’s property violated Defendant’s Fourth Amendment rights in this case. Here, an officer entered Defendant’s property, examined a stolen camper trailer and then, after obtaining Defendant’s consent, searched Defendant’s home. Defendant filed a motion to suppress, arguing that the officer’s examination of the camper was unconstitutional and tainted his subsequent consent to the search of his home. The district court denied the motion to suppress, concluding that because the camper was on a driveway that was impliedly open to the public, the officer’s entry onto Defendant’s property was lawful and that the officer had authority to seize the camper under the plain-view doctrine. The court of appeals reversed. The Supreme Court affirmed, holding (1) the camper was located on property that was afforded the constitutional protections of the home; and (2) the officer’s conduct was beyond the objectively reasonable scope of any implied license to enter Defendant’s property, and therefore, the warrantless search violated Defendant’s Fourth Amendment rights. View "State v. Chute" on Justia Law

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The Fifth Amendment privilege against self-incrimination does not protect a person from being ordered to prove a fingerprint to unlock a seized cellphone. The police lawfully seized a cellphone from Defendant and attempted to execute a valid warrant to search the cellphone, which had a fingerprint-scanner security lock that prevented the search. When Defendant refused to block the cellphone with his fingerprint the district court ordered Defendant to provide his fingerprint so the police could search the cellphone’s contents. The court of appeals affirmed, concluding that providing a fingerprint was not privileged under the Fifth Amendment. The Supreme Court affirmed, holding that because providing the fingerprint elicited only physical evidence from Defendant and did not reveal the contents of his mind, no violation of the Fifth Amendment privilege against self-incrimination occurred. View "State v. Diamond" on Justia Law

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Under the totality of the circumstances of this case, the police did not violate the Fourth Amendment when, during their execution of a warrant to search a home, they searched a purse that belonged to a guest at the home. Defendant was charged with third-degree controlled-substance crime for possessing methamphetamine. Defendant moved to suppress the methamphetamine found in her pursue, arguing that the search violated the Fourth Amendment because the search of her purse was beyond the scope of the search warrant. The district court denied the motion. The court of appeals affirmed. The Supreme Court affirmed, holding that, taken together, the facts showed that the search of Defendant’s purse was reasonable, and therefore, the search did not violate her Fourth Amendment rights. View "State v. Molnaux" on Justia Law