Justia Minnesota Supreme Court Opinion Summaries

After a jury trial, Appellant was convicted of first-degree premeditated murder and sentenced to life imprisonment without the possibility of release. The Supreme Court affirmed Appellant's conviction, holding (1) the record contained sufficient evidence to support the jury's verdict that Appellant, rather than an unidentified alternative perpetrator, was guilty of first-degree premeditated murder; and (2) based on State v. Brown and applying the factors set forth in State v. Lindsay, the trial court did not violate the public trial guarantees of the U.S. and Minnesota Constitutions by locking the courtroom doors before the State began its closing argument. View "State v. Silvernail" on Justia Law

Defendant was convicted of first-degree murder for the shooting death of Johanna Hollis and the attempted first-degree murder of Hollis's daughter. At trial, the State was only able to present a minimal amount of direct evidence connecting Defendant to the scene of the shooting. Thus, the State had to rely primarily on circumstantial evidence that included certain cellphone records. The records indicated that Defendant was in the vicinity of the shooting and supported the assertion by two witnesses that Defendant made threats to Hollis during a cellphone call Defendant placed to Hollis the night of the shooting. While Defendant's appeal was pending, a forensic expert conducted an examination of Defendant's cellphone. Defendant then petitioned for postconviction relief, alleging that the examination revealed Hollis could not have received the alleged threatening phone calls from Hollis's cellphone and that trial counsel provided ineffective assistance by failing to obtain Hollis's cellphone records and by failing to conduct a forensic examination of Hollis's cellphone. The postconviction court denied the petition without a hearing. The Supreme Court reversed, holding that Defendant met the threshold showing required to receive an evidentiary hearing on his ineffective-assistance-of-counsel claim. Remanded. View "State v. Nicks" on Justia Law

Defendant indicted of four counts of first-degree murder, one count of second-degree murder, and several related crimes arising out of the shooting death of his ex-wife and the kidnapping of their three children. Because Defendant pleaded not guilty by reason of mental illness, the district court bifurcated the trial. The jury found Defendant guilty of all counts and rejected his not-guilty-by-reason-of-mental-illness defense. The Supreme Court affirmed, holding that the district court (1) did not err by declining to remove a prospective juror for cause; (2) did not commit reversible error in making certain comments to the jury regarding the upcoming schedule of phase two of the trial; (3) may have erred in denying Defendant's request to testify on surrebuttal, but the error was harmless; (4) did not abuse its discretion when it determined that Defendant's nine-year-old daughter was incompetent to testify; and (5) did not abuse its discretion in failing to inquire into the nature of Defendant's pretrial complaints about counsel appointed to represent Defendant. In addition, the Court concluded that Defendant's pro se claims lacked merit. View "State v. Munt" on Justia Law

Defendant was found guilty of first-degree murder while committing domestic abuse with a past pattern of domestic abuse, and second-degree murder while committing a felony. The Supreme Court affirmed, holding (1) the State presented sufficient evidence to prove that Defendant assaulted the victim and caused his death; (2) the State presented sufficient evidence to prove Defendant had engaged in a past pattern of domestic abuse; (3) the district court did not err in failing to instruct the jury that a past pattern of domestic abuse requires proof beyond a reasonable doubt of at least two prior acts of abuse; and (4) the district court did not err in failing to instruct the jury that it needed to agree unanimously on which two specific acts of past abuse were proven beyond a reasonable doubt. View "State v. Hayes" on Justia Law

After a jury trial, Appellant was found guilty of first-degree murder and related charges. The district court sentenced Appellant on the first-degree murder conviction to a mandatory sentence of life imprisonment without the possibility of release. The Supreme Court affirmed Appellant's conviction and sentence on direct appeal. Appellant subsequently filed a second petition for postconviction relief, alleging that his sentence was unconstitutional under the Eighth Amendment. The postconviction court denied Appellant's petition without an evidentiary hearing, concluding that the petition was time barred and that none of the exceptions to the time bar applied. Appellant appealed, contending that his sentence violated the Eighth Amendment and that recent decisions of the U.S. Supreme Court satisfied an exception to the time bar. The Supreme Court affirmed, holding that the cases upon which Appellant relied were either not applicable to Appellant or did not apply retroactively to him. View "Chambers v. State" on Justia Law

Appellants were landowners who elected to require a utility to condemn their property in fee after Respondents sought to acquire easements through their property by eminent domain in order to construct a high-voltage electric transmission line. After making this election, Appellants requested that Respondents provide them with minimum compensation and relocation assistance. Respondents moved the district court for an order clarifying whether such benefits are available to property owners making an election under Minn. Stat. 216E.12. The district court concluded that such benefits were available to Appellants, but the court of appeals reversed. The Supreme Court reversed, holding that Appellants satisfied the statutory criteria for receiving minimum compensation and relocation assistance and were therefore entitled to such benefits. Remanded. View "N. States Power Co. v. Aleckson" on Justia Law

After a jury trial, Appellant was convicted of fleeing a peace officer by means other than a motor vehicle pursuant to Minn. Stat. 609.487(6) after she ran from a police officer who was responding to a stabbing at a bar. Appellant argued in a pretrial motion that she was entitled to a voluntary intoxication jury instruction because section 609.487(6) contains a specific-intent requirement. The district court denied the motion, ruling that the offense is a general-intent crime. The court of appeals affirmed. The Supreme Court affirmed but on different grounds, holding (1) section 609.487(6) contains a specific-intent requirement, and the district court erred in failing to instruct the jury on voluntary intoxication in this case; but (2) the error was harmless beyond a reasonable doubt because the omission of the voluntary intoxication jury instruction did not significantly affect the verdict. View "State v. Wilson" on Justia Law

Employees filed a complaint against two employers (Employers), alleging that Employers violated the Minnesota Human Rights Act (MHRA) based on sexual harassment perpetrated by the sole owner of both entities (Owner). Employees also alleged that Owner was individually liable under MHRA's aiding and abetting provision. The district court dismissed Employees' claims. The court of appeals reversed, holding (1) the district court's determination that the harassment was not actionable was clearly erroneous, (2) Employees were entitled to judgment on their claims as a matter of law, and (3) Owner could not be individually liable for aiding and abetting Employers' MHRA violations. The Supreme Court reversed, holding (1) the court of appeals did not err in concluding that Owner could not be liable on an aiding and abetting theory; but (2) two separate errors of law infected the district court's determination that Employees did not prove their sexual harassment claims, and therefore, the Court was unable to ascertain exactly how the errors impacted the court's decision to dismiss Employees' claims. Remanded to the district court to reevaluate the evidence using the correct legal standard. View "Rasmussen v. Two Harbors Fish Co." on Justia Law

After a jury trial, Appellant was convicted of premeditated first-degree murder. The Supreme Court affirmed on direct appeal. Appellant subsequently filed a petition for postconviction relief requesting a new trial or an evidentiary hearing based on recanted testimony from a witness and newly discovered evidence. The postconviction court denied Appellant's motion on the grounds that it was untimely because it was filed after the two-year statutory limit, and no exception to the limitations applied. The court further concluded that the jury would not have reached a different outcome without the witness's testimony. The Supreme Court affirmed, holding that Appellant's petition was untimely, and Appellant failed to demonstrate he was entitled to relief under the newly discovered evidence exception to the time bar. View "Clifton v. State" on Justia Law

After a trial, Appellant was convicted of first-degree murder while committing first-degree criminal sexual conduct and was sentenced to life in prison. On appeal, Appellant challenged his conviction on several grounds but did not raise an ineffective assistance of counsel claim. The Supreme Court affirmed. Appellant subsequently filed a petition for postconviction relief, asserting a claim of ineffective assistance of trial counsel. The district court summarily denied Appellant's petition. The Supreme Court affirmed, holding that Appellant's postconviction claim was barred by application of State v. Knaffla, which provides that claims that were not raised on direct appeal or were known or should have been known but were not raised on direct appeal, are procedurally barred. View "Sontoya v. State" on Justia Law