Justia Minnesota Supreme Court Opinion Summaries

After a jury trial, Appellant was convicted of two counts of first-degree murder. The Supreme Court affirmed the conviction, holding that the district court (1) did not err in admitting evidence from Appellant’s cell phone because the police lawfully seized the cell phone under the plain-view exception to the warrant requirement; (2) did not err in admitting evidence obtained from the execution of numerous search warrants because the search warrants were supported by probable cause; and (3) did not abuse its discretion in dismissing a juror for cause. View "State v. Holland" on Justia Law

After a jury trial, Defendant was convicted of third-degree criminal sexual conduct for sexually penetrating a member of the parish where he served as a priest. The court of appeals reversed and ordered a new trial, holding that the district court erred in (1) failing to provide a specific-unanimity instruction; (2) failing to instruct the jury that State was required to prove that Defendant had subjective knowledge of the purpose of the meeting at which sexual penetration occurred; and (3) denying Defendant’s motion to admit evidence of the complainant’s sexual history after it admitted the State’s evidence of the victim’s sexual inexperience. The Supreme Court reversed, holding (1) the district court’s failure to provide a specific-unanimity jury instruction did not affect Defendant’s substantial rights; (2) the clergy sexual conduct statute does not require the clergy member to know that the complainant seeks or is receiving spiritual counsel; and (3) even assuming the district court abused its discretion in disallowing Defendant’s sexual-history evidence, any error was harmless beyond a reasonable doubt. View "State v. Wenthe" on Justia Law

After a jury trial, Appellant was found guilty of first-degree murder committed for the benefit of a gang and first-degree premeditated murder. Appellant was convicted of first-degree premeditated murder, and the district court imposed a sentence of life without the possibility of release. The Supreme Court affirmed. Appellant later filed a petition for postconviction relief, alleging, inter alia, newly discovered evidence of the recantations of two witnesses. The Supreme Court remanded the case to the postconviction court for an evidentiary hearing on the witness recantation claim. Thereafter, Appellant filed a second petition for postconviction relief, alleging that his sentence was unconstitutional and that he was entitled to retroactive application of Miller v. Alabama. The postconviction court consolidated both matters, conducted an evidentiary hearing, and (1) denied Appellant’s witness recantation claim from his first postconviction petition, and (2) denied Appellant’s second postconviction petition. The Supreme Court affirmed, holding (1) Appellant was not entitled to a new trial on his witness recantation claim; and (2) Appellant’s second petition for postconviction relief was time-barred. View "Martin v. State" on Justia Law

After a jury trial, Appellant was convicted of two counts of first-degree murder, one count of attempted first-degree murder, and one count of burglary. Appellant committed the offenses when he was sixteen years old. The district court imposed a mandatory sentence of life imprisonment with the possibility of release for each first-degree murder conviction. Defendant’s convictions were affirmed on direct appeal. Nineteen years later, Appellant moved to correct his sentence based on the rule announced in Miller v. Alabama. Specifically, Appellant argued that the rule announced in Miller should be extended to statutory provisions that mandate the imposition of life imprisonment with the possibility of release and should apply to a district court’s discretionary imposition of consecutive sentences that are the functional equivalent of life imprisonment without the possibility of release. The postconviction court denied Appellant’s motion. The Supreme Court affirmed, holding that the postconviction court’s decision was consistent with the Court’s recent rulings, and its ruling was a sound exercise of its discretion. View "State v. Williams" on Justia Law

Defendant was convicted of three counts of murder in connection with the death of his two-year-old niece. While Defendant’s appeal was pending, new evidence was identified. The State then sought, and a grand jury returned, an amended indictment for five counts of murder. After a new trial, Defendant was convicted of five counts of murder. The Supreme Court reversed, holding that the district court (1) did not err when it seated jurors who knew about Defendant’s first conviction; but (2) abused its discretion when it allowed a juror who exhibited actual bias against Defendant and was not adequately rehabilitated to sit in judgment of Defendant. Remanded for a new trial. View "State v. Fraga" on Justia Law

After a jury trial, Appellant was found guilty of first-degree premeditated murder and first-degree felony murder. The district court sentenced Appellant to life imprisonment without the possibility of release on the first-degree premeditated murder conviction. The Supreme Court affirmed, holding (1) the district court did not err in denying Appellant’s motion to suppress statements he made to police; (2) the district court did not abuse its discretion when it declined to give Appellant’s requested jury instruction on circumstantial evidence; and (3) the evidence was sufficient to support Appellant’s murder convictions. View "State v. Fox" on Justia Law

After a jury trial, Appellant was found guilty of failing to register as a predatory offender. The district court imposed a presumptive sentence of sixteen months imprisonment and a ten-year conditional-release term under Minn. Stat. 422.052(3). The court imposed the conditional-release term based on a previous finding by an administrative committee of the Department of Corrections that had assessed Appellant as a high-risk, level-III offender. Several years later, Appellant moved to correct his sentence, arguing that a jury, not the judge, was constitutionally required to make the finding regarding his risk-level status. The district court denied Appellant’s motion. The court of appeals affirmed. The Supreme Court reversed and vacated Appellant’s ten-year conditional-release term, holding that Appellant had the right to have a jury determine whether he was a risk-level-III offender at the time of his offense. View "State v. Her" on Justia Law

After a jury trial, Defendant was convicted of first-degree premeditated murder and sentenced to life imprisonment without the possibility of release. The conviction arose from a homicide that occurred during an aggravated robbery. The Supreme Court affirmed, holding (1) the evidence was sufficient to uphold Defendant’s conviction, as the State introduced sufficient evidence to prove Defendant’s guilt as an accomplice to the murder; and (2) any error in the district court’s admission into evidence of recordings of portions of Defendant’s interrogation that occurred after Defendant told the officers, “ain’t no sense in talking no more man” was harmless beyond a reasonable doubt because the verdict was surely unattributable to the error. View "State v. McAllister" on Justia Law

After a jury trial, Appellant was convicted of first-degree premeditated murder and first-degree murder while committing burglary arising from the stabbing death of an eleven-year-old. The Supreme Court affirmed Appellant’s conviction for premeditated first-degree murder but vacated his conviction for first-degree murder while committing burglary. Appellant later filed a petition for postconviction relief arguing that he was entitled to a new trial to consider evidence that was purportedly new and exculpatory. The postconviction court denied the petition without holding an evidentiary hearing. Appellant subsequently brought the instant pro se petition for postconviction relief, alleging ineffective assistance of trial counsel and appellate counsel and loss of evidence claims. The postconviction court summarily denied the petition, concluding (1) appellate counsel’s representation did not fall below an objective standard of reasonableness, and (2) Appellant’s remaining claims were procedurally barred under State v. Knaffla. The Supreme Court affirmed, holding (1) Appellant’s ineffective assistance of appellate counsel claim failed as a matter of law; and (2) Appellant’s remaining claims were time barred. View "Fort v. State" on Justia Law

Appellant was convicted of first-degree premeditated murder and sentenced to life imprisonment without the possibility of release. The Supreme Court affirmed on appeal. Appellant later filed a pro se petition for postconviction relief, raising a sentencing claim, a restitution claim, and several claims of ineffective assistance of counsel and newly discovered evidence. The postconviction court granted relief on Appellant’s sentencing claim but denied relief on his other claims. Appellant appealed, arguing that the postconviction court erred when it denied his claims without an evidentiary hearing. The Supreme Court affirmed, holding that the postconviction court did not err when it summarily denied Appellant’s petition. View "Nissalke v. State" on Justia Law