Articles Posted in Civil Rights

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The Supreme Court declined Appellants’ invitation to depart from the United States Supreme Court’s decision in Camara v. Municipal Court, 387 U.S. 523 (1967) and hold that Minnesota’s constitution requires that an administrative search warrant be supported by probable cause of the sort required in a criminal investigation. Camara held that an administrative warrant satisfies the probable cause requirement if reasonable legislative or administrative standards for conducting an unconsented-to rental housing inspection are satisfied with respect to a particular dwelling. In this case, the City of Golden Valley petitioned the district court for an administrative search warrant to search rental property for compliance with the city code. The district court denied the petition for the administrative search warrant, concluding that the issuance of such a search warrant was foreclosed without suspicion of a code violation. The court of appeals reversed. The Supreme Court affirmed, holding that the Minnesota Constitution does not require individualized suspicion of a code violation to support an administrative search warrant for a rental housing inspection. View "City of Golden Valley v. Wiebesick" on Justia Law

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Appellant, a juvenile offender, challenged the district court’s imposition of three consecutive sentences of life imprisonment with the possibility of release after thirty years on each sentence for his three murder convictions. Appellant argued, among other things, that the rule announced in Miller v. Alabama and clarified in Montgomery v. Louisiana should apply to his case because his consecutive sentences were, in the aggregate, the functional equivalent of life imprisonment without the possibility of release. The Supreme Court affirmed, holding (1) this court declines to extend the Miller/Montgomery to include Appellant or other similarly situated offenders because the United States Supreme Court has not squarely addressed the issue of whether consecutive sentences should be viewed separately when conducting a proportionality analysis; and (2) Appellant’s three consecutive sentences do no unfairly exaggerate the criminality of his conduct. View "State v. Ali" on Justia Law

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Respondent worked as a police officer for Appellant City of Minneapolis. When the City transferred Respondent from his position with the Violent Offender Task Force to another police unit Respondent was fifty-four years old. In November 2011, Respondent filed a complaint with Appellant’s human resources department, claiming that the transfer was due to age discrimination. More than one year after Peterson filed his complaint, Appellant concluded that the transfer was not because of age discrimination. In March 2014, Respondent commenced this action against Appellant, claiming that the City discriminated against him based on his age in violation of the Minnesota Human Rights Act (MHRA). The district court granted partial summary judgment for the City, concluding that Respondent’s claim was not filed within the relevant one-year limitations period. The court of appeals reversed, concluding that the statute of limitations was suspended during the period of time in which Appellant’s human resources department was investigating Respondent’s claim. The Supreme Court affirmed, holding that Respondent and Appellant were voluntarily engaged in a dispute resolution process involving a claim of unlawful discrimination during Appellant’s investigation of Respondent’s claim, which triggered Minn. Stat. 363A.28(3)(b) and suspended the one-year limitations period. View "Peterson v. City of Minneapolis" on Justia Law

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After Nicole LaPoint applied for a job with Family Orthodontics, the company’s owner, Dr. Angela Ross, offered LaPoint a job as an orthodontic assistant. When LaPoint told Dr. Ross that she was pregnant, Family Orthodontics rescinded its job offer. LaPoint sued the company for sex discrimination under the Minnesota Human Rights Act. The district court entered judgment in favor of Family Orthodontics. The court of appeals reversed, ruling, as a matter of law, that Family Orthodontics had discriminated against LaPoint because of her pregnancy. The Supreme Court reversed, holding (1) to the extent the court of appeals applied an incorrect legal standard to evaluate LaPoint’s claim, it erred; and (2) the district court’s findings were reasonably supported by the evidence, but it was unclear whether the district court would have made the same findings had it applied the correct law regarding animus. Remanded. View "LaPoint v. Family Orthodontics, P.A." on Justia Law

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Defendant was charged in May 2013 with two counts of first-degree criminal sexual conduct. When Defendant failed to appear for his first appearance, the district court issued a warrant for his arrest. In February 2015, Defendant was arrested for unrelated reasons. Before his omnibus hearing, Defendant moved to dismiss the charges, claiming that the twenty-one-month delay between the date he was charged and his eventual arrest violated his right to a speedy trial under the United States and Minnesota Constitutions. The district court granted Defendant’s motion and dismissed the charges after applying the four-factor balancing test from Barker v. Wingo. The court of appeals reversed, concluding that the third and fourth Barker factors did not weigh in Defendant’s favor, and therefore, on balance, the State had not violated Defendant’s constitutional right to a speedy trial. The Supreme Court affirmed as modified, holding that although the delay may have been attributable to the State’s negligence, Defendant’s failure to assert his speedy trial right weighed heavily against him and ultimately led to the conclusion that the State did not violate Defendant’s right to a speedy trial. View "State v. Osorio" on Justia Law

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The State charged Defendant under Minn. Stat. 609.352, subd. 2a(2) with felony communication with a child describing sexual conduct after she sent sexually explicit images and messages to a fifteen-year-old boy. Defendant filed a motion to dismiss, arguing that section 609.352, subd. 2a(2) proscribes a substantial amount of speech that the First Amendment protects and thus facially violates the First Amendment. The district court concluded that the statute violates the First Amendment, and the court of appeals affirmed. The Supreme Court reversed, holding that 609.352, subd. 2a(2) is not substantially overbroad in relation to its plainly legitimate sweep. View "State v. Muccio" on Justia Law

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After Appellant pleaded guilty to third-degree criminal sexual conduct, removal proceedings were initiated against him. In an attempt to avoid deportation, Appellant filed an emergency motion to withdraw his guilty plea, arguing, inter alia, that he received ineffective assistance of counsel because counsel failed accurately to inform him that his plea would lead to his removal from the United States. Specifically, Appellant argued that Padilla v. Kentucky required his attorney to advise him that the plea would result in his deportation, rather than just the deportation was a possibility. The postconviction court denied Appellant’s motion. The court of appeals affirmed. The Supreme Court affirmed, holding that Padilla did not require Appellant’s counsel to do anything more than provide a general warning about the immigration consequences of entering the plea, and therefore, Appellant’s counsel satisfied his obligation under the Sixth Amendment. View "Sanchez v. State" on Justia Law

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Defendant was arrested and charged with drug-related crimes. The district court ordered Defendant’s pretrial release. The district court later found probable cause that Defendant had violated the conditions of her release and issued a warrant for her arrest. Officers then went to the residence of Defendant’s boyfriend. One officer opened an unlocked door, went inside, and arrested Defendant. While arresting her, the officer saw marijuana and a bong in plain view. Law enforcement then obtained a search warrant for the apartment of Defendant’s boyfriend. The state subsequently charged Defendant with two counts of fifth-degree possession of a controlled substance and possession of drug paraphernalia. The district court suppressed all fruits of Defendant’s arrest and dismissed the charges, concluding that the arrest was illegal because the warrant for Defendant's arrest did not authorize police to enter her boyfriend’s apartment. The court of appeals reversed. The Supreme Court affirmed, holding that neither the Fourth Amendment of the U.S. Constitution nor Article I, Section 10 of the Minnesota Constitution requires police to obtain a search warrant before entering a home to arrest a guest who is the subject of a lawfully issued arrest warrant. View "State v. deLottinville" on Justia Law

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Defendant pled guilty to felony domestic assault in district court. Following sentencing, Ramsey County Community Corrections notified the district court that Defendant was required to register as a predatory offender due to his conviction. Defendant filed a motion to withdraw his guilty plea on the ground that he had not been aware that his conviction would trigger the requirement to register as a predatory offender. The district court denied the request. The court of appeals affirmed. The Supreme Court affirmed, holding that a defense attorney’s failure to advise a defendant about predatory offender registration requirements before the defendant enters a plea of guilty does not violate a defendant’s right to effective assistance of counsel, and therefore, Defendant was not entitled to withdraw his guilty plea. View "Taylor v. State" on Justia Law

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Appellant was convicted of first-degree murder for the benefit of a gang on an accomplice-liability theory. The Supreme Court affirmed. After unsuccessfully filing two postconviction petitions, Appellant filed a third postconviction petition in which he alleged that three witnesses presented false testimony at his trial. Following an evidentiary hearing, the postconviction court denied Appellant’s third postconviction petition. The Supreme Court affirmed, holding (1) the postconviction court did not err when it rejected Appellant’s claim that the prosecutor intimidated a recanting witness when it apprised the witness of his Fifth Amendment rights; and (2) the postconviction court did not err when it struck the testimony the witness gave before invoking his Fifth Amendment privilege. View "Caldwell v. State" on Justia Law