Justia Minnesota Supreme Court Opinion Summaries

Articles Posted in Civil Rights
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The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court finding Defendant guilty of violating a domestic abuse no contact order (DANCO), holding that the State did not violate Defendant's rights under the Minnesota Uniform Mandatory Disposition of Detainers Act (UMDDA).Defendant made a proper request for a final disposition under the UMDDA, and the State dismissed the charges pending against him. Nearly one year later, the State refiled the charges and brought Defendant to trial. The Supreme Court affirmed the resulting conviction, holding (1) once the State dismissed the pending complaint, Defendant no longer enjoyed a right to disposition of that complaint under the UMDDA; (2) the delay between Defendant's speedy trial request and his trial did not violate his constitutional right to a speedy trial; and (3) the district court did not abuse its discretion by declining to dismiss the State's complaint under Minn. R. Crim. P. 30.02. View "State v. Mikell" on Justia Law

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The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's conviction of theft under a principal theory of criminal liability and of being an indelible person in possession of a firearm, holding that the district court erred when it failed to conduct a Confrontation Clause analysis surrounding the testimonial statement of a nontestifying co-conspirator, but the error was harmless.On appeal, Defendant argued that the district court violated his right to confrontation by admitting his co-conspirator's statements to the police when Defendant had no opportunity to cross-examine his co-conspirator. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the district court violated Defendant's right to confrontation when it admitted the disputed statements into evidence at trial; but (2) the violation of the Confrontation Clause was harmless beyond a reasonable doubt. View "State v. Sutter" on Justia Law

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The Supreme Court affirmed in part and reversed in part the decision of the court of appeals affirming the decision of the district court granting the Commissioner of Correction's motion to dismiss Plaintiff's action seeking declaratory and injunctive relief, holding that some of the facts alleged in the complaint stated a claim upon which relief could be granted.Defendant pleaded guilty with several crimes. After Defendant began serving his sentence the Commissioner denied his application for the Challenge Incarceration Program on the grounds that persons required to register as predatory offenders are not eligible for that program. Defendant then brought this action alleging that the predatory offender registration statute and some of its collateral consequences denied him due process as applied to his charged, but not convicted, enumerated offense of kidnapping. The court of appeals affirmed. The Supreme Court affirmed in part and reversed in part, holding that the district court erred in dismissing Defendant's claim of substantive and procedural due process violations based on his alleged fundamental right to parent his child. View "Werlich v. Schnell" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction, holding that the State's discovery motion at Defendant's first court appearance seeking to photograph transitory scratches on Defendant's arms was not a critical stage of the criminal proceeding that required the presence of defense counsel.At Defendant's first appearance on criminal sexual conduct charges the State made a discovery motion to take photographs of transitory scratch marks on Defendant's arms. At issue was whether the discovery motion was a critical stage of the proceedings entitling Defendant to have counsel present. The court of appeals concluded that the discovery hearing on the "otherwise-valid" discovery request to noninvasively photograph scratches was not a critical stage of the proceedings. The Supreme Court affirmed, holding that there was no violation of Defendant's Sixth Amendment right to counsel under the circumstances of this case. View "State v. Zaldivar-Proenza" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals affirming the district court's denial of Appellant's petition for postconviction relief after determining that his stay of adjudication and discharge from probation was not a conviction, holding that Appellant's stay of adjudication was not a conviction.Pursuant to a plea agreement, Appellant pleaded guilty to domestic assault-intentional infliction of bodily harm. The district court accepted Appellant's plea of guilty and stayed adjudication under the parties' agreement. After Appellant successfully completed and was discharged from probation he received notice that he was scheduled for immigration removal proceedings. Appellant filed a petition for postconviction relief seeking to withdraw his guilty plea on grounds that he received ineffective assistance of counsel under Padilla v. Kentucky, 559 U.S. 356 (2010). The postconviction court concluded that Appellant had not been convicted of a crime and was therefore not eligible for postconviction relief. The Supreme Court affirmed, holding (1) the plain meaning of the phrase "a person convicted of a crime" in Minn. Stat. 590.01, subd. 1 means a person who has a conviction under Minnesota law; and (2) Appellant's stay of adjudication did not meet this definition. View "Johnston v. State" on Justia Law

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The Supreme Court reversed the decision of the court of appeals reversing the judgment of the district court finding that Minn. Stat. 617.261 was unconstitutional under the First Amendment, holding that the statute does not violate the First Amendment because it survives strict scrutiny.Defendant was charged with a felony-level violation of Minn. Stat. 617.261, the statute that criminalizes the nonconsensual dissemination of private sexual images. Defendant moved to dismiss the charge on constitutional grounds. The district court denied the motion, concluding that the conduct regulated by the statute is entirely unprotected obscene speech and that any degree of overbreadth was insubstantial. The court of appeals reversed, concluding that the statute is unconstitutionally overbroad because it criminalizes a substantial amount of protected speech. The Supreme Court reversed, holding (1) section 617.261 prohibits more than obscenity; but (2) the restriction does not violate the First Amendment because it is justified by a compelling government interest and is narrowly tailored to serve that interest. View "State v. Casillas" on Justia Law

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The Supreme Court affirmed in part and reversed in part the decision of the court of appeals affirming the judgment of the district court dismissing Plaintiff's Minnesota Human Rights Act and common-law negligence claims against a university and a hospital for race- and sex-based discrimination, holding that the district court erred in dismissing Plaintiff's employment discrimination claim under the Act and Plaintiff's common-law negligence claims.Plaintiff's claims stemmed from discrimination she allegedly experienced during a practicum program as a graduate student. The district court dismissed Plaintiff's claims under the Act as time barred and dismissed her common-law negligence claims for failure to establish that Defendants owed her a common-law duty separate from the obligations owed under the Act. The court of appeals affirmed. The Supreme Court affirmed in part and reversed in part, holding (1) Plaintiff's employment discrimination claim under the act against Allina Health System was timely, and the district court erred in determining that Plaintiff's lack of compensation from the practicum barred her claim; (2) Plaintiff's remaining statutory discrimination claims against Defendants were time barred; and (3) Plaintiff alleged sufficient facts to maintain her common-law negligence claims. View "Abel v. Abbott Northwestern Hospital" on Justia Law

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The Supreme Court affirmed the judgment of the court of appeals concluding that an ordinance adopted by the City of Minneapolis that prohibits certain property owners, property managers, and others from refusing to rent property to prospective tenants in order to avoid the burden of complying with the requirements of Section 8 of the United States Housing Act survives due process and equal protection rational basis scrutiny, holding that the ordinance is constitutional.Plaintiffs, property owners who owned and rented residential properties in the City, alleged, among other things, that the ordinance violated the Due Process Clause and the Equal Protection Clause of the Minnesota Constitution. The district court granted summary judgment in favor of Plaintiffs, concluding that the ordinance violated equal protection and due process protections. The court of appeals reversed on both claims. The Supreme Court affirmed, holding that the Minneapolis ordinance did not violate the Minnesota Constitution's guarantee of substantive due process or equal protection guarantee. View "Fletcher Properties, Inc. v. City of Minneapolis" on Justia Law

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The Supreme Court affirmed the judgment of the district court denying Defendant's petition for postconviction relief arguing that the rule announced in Miller v. Alabama, 567 U.S. 460 (2012), and later clarified in Montgomery v. Louisiana, 577 U.S. __ (2016), should be extended to adult offenders whose crimes reflect the transient immaturity of youth, holding that the district court did not abuse its discretion when it denied Defendant's postconviction petition.Defendant was convicted of first-degree premeditated murder and sentenced to a mandatory term of life in prison without the possibility of release. Defendant was eighteen years and seven days old on the date of the offense. On appeal from the denial of his postconviction motion, Defendant renewed his Miller/Montgomery argument and further asked the Supreme Court to interpret Minn. Const. art. I, 5 to provide greater protection than the Eighth Amendment. The Supreme Court affirmed, holding (1) because the Miller/Montgomery rule is clearly limited to juvenile offenders under the age of eighteen at the time of the offense, the district court did not abuse its discretion when it denied Defendant's petition for postconviction relief; and (2) Defendant forfeited appellate review of his claim under the Minnesota Constitution. View "Nelson v. State" on Justia Law

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The Supreme Court affirmed the judgment of the district court and the court of appeals concluding that Minn. Stat. 609.27 subd. 1(4) was constitutionally overbroad and could not be saved through a narrowing construction or by severing part of it, holding that subdivision 1(4) criminalizes a substantial amount of protected speech and is thus unconstitutional on its face.Defendant was charged with one felony count of attempted coercion under section 609.275, the attempted coercion statute. Defendant filed a motion to dismiss, arguing that the statute was overly broad in violation of the First Amendment. The district court granted the motion to dismiss, and the court of appeals affirmed. The Supreme Court affirmed, holding that Minn. Stat. 609.27 subd. 1(4) is substantially overbroad and cannot be narrowed or saved by severance and therefore must be invalidated as violating the First Amendment. View "State v. Jorgenson" on Justia Law