Justia Minnesota Supreme Court Opinion Summaries

Law enforcement officers searched Defendant’s home pursuant to a search warrant and found plastic bags containing methamphetamine. The search warrant was based on information police received from a warrantless search of Defendant’s garbage. Defendant was charged with third-degree possession of a controlled substance. Defendant moved to suppress the evidence, arguing that the warrantless search of his garbage violated Minn. Const. art. I, 10. The district court denied the motion to suppress. The court of appeals affirmed. At issue before the Supreme Court was whether Article I, Section 10 of the Minnesota Constitution requires greater protection than the Fourth Amendment to the United States Constitution in the context of a warrantless search of garbage set out for collection in an area accessible to the public. The Supreme Court affirmed, holding (1) there is not a principled basis for interpreting Article I, Section 10 to require greater protection that the Fourth Amendment; (2) it was lawful for the police to obtain Defendant’s garbage from the garbage collector; and (3) because the warrantless search of Defendant’s garbage was reasonable under the state and federal constitutions, the search warrant for Defendant’s residence based on evidence found in the garbage was valid. View "State v. McMurray" on Justia Law

Appellant was convicted of a crime and was sentenced to a stayed sentence of ninety-eight months together with a conditional-release term of five years. Appellant violated his probation, served a portion of his executed sentence, and was then placed on supervised release. After Appellant violated the terms of his supervised release, the Minnesota Department of Corrections (DOC) revoked his release and ordered him to serve the remaining portion of his executed sentence in custody. Appellant filed a motion to correct his sentence under Minn. R. Crim. P. 27.03(9), alleging that the DOC had illegally extended his conditional-release term. The district court concluded that it had jurisdiction over the matter and denied Appellant’s motion to correct his sentence on the merits. The Supreme Court affirmed as modified, holding (1) the district court has subject matter jurisdiction over a motion to correct a sentence under Rule 27.03(9), but such a motion is not the proper procedure to obtain judicial review of the Commissioner of Correction’s administrative decision implementing the sentence imposed by the district court; and (2) because Appellant used the wrong procedure, a denial of his motion to correct his sentence was warranted. View "State v. Schnagl" on Justia Law

Minn. Stat. 169A.20(2) (“the test refusal statute”) makes it a crime for a driver to refuse to request to take a chemical test to detect the presence of alcohol if certain conditions are met. One of those conditions is that the driver has been validly arrested for driving while impaired. Appellant argued that the test refusal statute violated due process because it criminalizes refusal to consent to an unreasonable, warrantless search of a driver’s breath. The district court dismissed the charges, concluding that the police lacked a lawful basis to search Appellant without a warrant, and therefore, the test refusal statute was unconstitutional as applied. The court of appeals reversed. The Supreme Court affirmed, holding (1) because the breath test the police asked Defendant to take would have been constitutional under the search-incident-to-arrest exception to the Fourth Amendment’s warrant requirement, charging Defendant with criminal test refusal did not implicate a fundamental right; and (2) the test refusal statute is a reasonable means to a permissive object and passes rational basis review. View "State v. Bernard" on Justia Law

After a jury trial, Appellant was convicted of premeditated first-degree murder and attempted first-degree murder. In a postconviction motion, Appellant argued that he was entitled to a new trial based on newly discovered evidence and the recantation of two witnesses. The postconviction court denied the petition after granting multiple continuances for Appellant to attempt to secure the appearance of favorable witnesses and then holding an evidentiary hearing. The Supreme Court affirmed on the merits but remanded for resentencing, holding (1) the postconviction court did not err when it refused to compel the attendance of certain witnesses at an evidentiary hearing; (2) Appellant forfeited his argument that his trial counsel provided ineffective assistance; and (3) the sentence imposed after a remand from Appellant’s direct appeal was improper. Remanded for resentencing. View "Burrell v. State" on Justia Law

Appellant pleaded guilty and was convicted of first-degree burglary. Two years after Appellant was placed on probation, he appeared before the district court regarding alleged probation violations. Appellant personally admitted the probation violations, and the district court revoked his probation. On appeal, Appellant argued for the first time that the district court erred when it violated his constitutional right to be advised of his due process rights under Morrissey v. Brewer and when it failed to provide him the rights advisory required by Minn. R. Crim. P. 27.04. The court of appeals affirmed. The Supreme Court affirmed, holding (1) a probationer does not have a separate constitutional right “to be advised” that he or she has the procedural due process rights articulated in Morrissey; and (2) the district court’s plain error in failing to provide Appellant the rights advisory requirement by Rule 27.04 did not affect his substantial rights. View "State v. Beaulieu" on Justia Law

After a jury trial, Appellant was convicted of first-degree domestic-abuse murder and two counts of second-degree murder. Appellant was sentenced to life imprisonment with the possibility of release. The Supreme Court affirmed, holding (1) two courtroom closures did not violate Defendant’s Sixth Amendment right to a public trial because Defendant requested the courtroom closures, and the closures did not seriously affect the fairness, integrity, or public reputation of the judicial proceedings; and (2) any error in the admission of relationship evidence under Minn. Stat. 634.20 of Defendant’s past incidents of domestic abuse against his sister and his former girlfriend was harmless. View "State v. Benton" on Justia Law

Upon executing a warrant to search Defendant’s home for stolen property, law enforcement officers found a locked gun safe in the bedroom. Inside the gun safe were a sawed-off shotgun, a full-length shotgun, and a pistol. No evidence identified Defendant as the owner of the sawed-off shotgun or the pistol. After a jury trial, Defendant was convicted of being a felon in possession of a firearm, in possession of a firearm with no serial number, and in possession of a short-barreled shotgun. Defendant appealed, arguing that there was insufficient evidence that he constructively possessed the firearms in the locked safe. The court of appeals affirmed. The Supreme Court affirmed, holding that under the first prong of State v. Florine, the State established Defendant’s constructive possession of the guns by direct evidence, and therefore, the evidence was sufficient to support the convictions. View "State v. Salyers" on Justia Law

After a jury trial, Appellant was convicted of one count of first-degree premeditated murder and two counts of first-degree felony murder. The Supreme Court consolidated Appellant’s direct appeal and his postconviction appeal and held (1) the mandatory imposition of life without the possibility of release (LWOR) on the first-degree premeditated murder conviction violated the Eighth Amendment’s prohibition on cruel and unusual punishment under Miller v. Alabama; and (2) the postconviction court did not err in denying postconviction relief, the district court did not err in its evidentiary rulings or in imposing consecutive sentences, and the arguments Appellant raised in a pro se supplemental brief were without merit. Remanded for resentencing on the first-degree premeditated murder conviction. View "State v. Ali" on Justia Law

Following a bench trial, Appellant was convicted of three counts of first-degree premeditated murder and sentenced to three consecutive life sentences without the possibility of release. The Supreme Court affirmed Appellant’s convictions on direct appeal, holding (1) the district court did not err in admitting an in-court identification of Appellant; (2) the district court did not abuse its discretion in excluding Appellant’s proposed expert testimony regarding the problems with eyewitness identification; and (3) Appellant was not entitled to a new trial based on alleged prosecutorial misconduct in eliciting three types of inadmissible character evidence. View "State v. Mosley" on Justia Law

Appellant was charged with, and pleaded guilty to, first-degree murder while committing domestic abuse. The district court accepted Appellant’s guilty plea, convicted him, and sentenced him to life imprisonment with the possibility of release. Appellant later filed a motion to withdraw his guilty plea, asserting that enforcing his guilty plea was manifestly unjust because the plea was not accurate, intelligent, or voluntary. The postconviction court denied relief. The Supreme Court affirmed. Appellant then filed a second postconviction petition, alleging that his guilty plea was inaccurate and that the attorney who represented him on his first postconviction petition provided ineffective assistance. The postconviction court denied the petition without an evidentiary hearing. The Supreme Court affirmed, holding that the postconviction court (1) did not abuse its discretion when it concluded that Appellant’s challenge to his guilty plea was procedurally barred; and (2) did not abuse its discretion when it summarily denied Appellant’s ineffective assistance of postconviction counsel claim because the petition and records conclusively showed that Appellant was not entitled to relief. View "Lussier v. State" on Justia Law