Justia Minnesota Supreme Court Opinion Summaries

After the City of Moorhead annexed Americana Estates (Americana), a residential subdivision with sixty-five metered electric service accounts, the City filed a condemnation petition to begin municipal electric service to residents of Americana. After a hearing, a three-member commission of the district court awarded the Red River Valley Cooperative Power Association (RRVC), which previously served Americana, $307,214. Both parties appealed the commission's award of damages. After a jury trial, the district court awarded a total compensation award to RRVC of $385,311. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the City's valuation was inconsistent with the plain language of Minn. Stat. 216B.47 by failing to give meaningful consideration to four statutory factors and thus was properly excluded from consideration by the district court; and (2) the district court did not abuse its discretion in excluding portions of an untimely revised report submitted by the City dealing with facility replacement costs. View "City of Moorhead v. Red River Valley Coop. Power Ass'n" on Justia Law

Appellant was convicted of first-degree murder while committing first-degree criminal sexual conduct causing personal injury. The Supreme Court affirmed the conviction on appeal. Appellant subsequently filed a petition for postconviction relief, alleging a claim of newly discovered evidence. After an evidentiary hearing, the postconviction court denied the petition, concluding that the newly discovered evidence was not credible and, therefore, was not likely to produce a result more favorable to Appellant. The Supreme Court affirmed, holding that the postconviction court did not abuse its discretion in denying Appellant's petition for postconviction relief, as the record supported the court's credibility determinations. View "Tscheu v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree premeditated murder, second-degree intentional murder, and second-degree unintentional murder while committing a felony. Defendant appealed, seeking a new trial based on the district court's allegedly erroneous admission of expert testimony offered by a medical examiner and a firearms examiner. Defendant argued that the testimony was improperly admitted because it intruded on the fact-finding role of the jury. Defendant did not object to the testimony at trial. The Supreme Court affirmed Defendant's convictions, holding that the district court properly admitted the expert testimony of the medical examiner and the firearms examiner. View "State v. Xiong" on Justia Law

Defendant was charged with several misdemeanor offenses, including driving a motor vehicle with a blood-alcohol concentration of 0.08 percent or more. Defendant filed a request to preserve "blood tests," but subsequently, the State destroyed Defendant's blood sample used in a blood alcohol test in accordance with its retention policy. Defendant pleaded not guilty and successfully moved to suppress the results of his blood-alcohol test. The court of appeals affirmed the district court's suppression order, adopting a per se rule requiring suppression when the State destroys evidence after a defendant has made a demand to preserve the evidence. The Supreme Court reversed, holding that the State did not violate any of the Minnesota Rules of Criminal Procedure when it destroyed Defendant's blood sample, and the district court erred in suppressing the results of the blood test. View "State v. Hawkinson" on Justia Law

After a jury trial, Defendant was convicted of first-degree premeditated murder, first-degree intentional drive-by shooting murder, attempted first-degree premeditated murder, and attempted first-degree intentional drive-by shooting murder. Defendant filed two petitions for postconviction relief, both of which were denied. Several years after his convictions, Defendant filed a third petition for postconviction relief, arguing that the grand jury selection process in Hennepin County violated his constitutional rights to due process and equal protection. Defendant maintained that his current petition was excepted from the statutory two-year time limit. The postconviction court denied Defendant's petition for postconviction relief, concluding that the petition was time barred and that the newly-discovered-evidence exception did not apply and alternatively, that the petition was barred under the Knaffla doctrine. The Supreme Court affirmed, holding that Defendant's petition failed to satisfy an exception to the two-year limitations period, and therefore, the petition was time barred. View "Francis v. State" on Justia Law

Defendant was convicted in 1990 of first-degree premeditated murder. The Supreme Court affirmed the conviction on direct appeal. Defendant subsequently filed a petition for postconviction relief requesting an evidentiary hearing to consider evidence he asserted was new and exculpatory. Specifically, Defendant sought a hearing to consider (1) newly discovered eyewitness testimony, which he claimed buttressed his alternative-perpetrator theory, and (2) whether he was entitled to have DNA testing of a sample from a smear found at the crime scene. The postconviction court denied Defendant's petition and motion without an evidentiary hearing, concluding that Defendant did not meet the standard for receiving an evidentiary hearing. The Supreme Court affirmed, holding that Defendant failed to meet the threshold required for relief, and thus, the postconviction court did not abuse its discretion when it denied Defendant's motion without an evidentiary hearing. View "Fort v. State" on Justia Law

After a jury trial, Appellant was found guilty of first-degree premeditated murder. On appeal, the Supreme Court affirmed the conviction. Appellant subsequently filed a petition for postconviction relief alleging seven separate grounds he contended warranted a new trial. The postconviction court summarily denied Appellant's petition, explaining that Appellant's claims were either meritless on their face or barred by State v. Knaffla. The Supreme Court affirmed, holding that the postconviction court properly determined that the petition and files and records of the trial conclusively showed Appellant was not entitled to postconviction relief because his claims were either meritless on their face or barred by the Knaffla rule. View "Anderson v. State" on Justia Law

Defendant was convicted for first-degree murder and attempted first-degree murder. After Defendant's convictions were affirmed on appeal, Defendant filed four separate petitions for postconviction relief, each of which was denied by the postconviction court. Defendant filed a fifth petition for postconviction relief, arguing that (1) he was entitled to relief based on newly discovered evidence of false testimony, and (2) the statute under which he was convicted was unconstitutional. The postconviction court denied Defendant's petition. The Supreme Court affirmed, holding (1) based on the postconviction court's findings, the court did not abuse its discretion when it summarily denied Defendant's claim of newly discovered evidence; and (2) Defendant's claim that the statute under which he was convicted was unconstitutional was time-barred. View "McDonough v. State" on Justia Law

A jury found Defendant guilty of first-degree felony murder while committing a drive-by shooting and second-degree intentional murder. The district court convicted Defendant of first-degree felony murder and sentenced him to life imprisonment with the possibility of release. The Supreme Court reversed Defendant's conviction of first-degree felony murder while committing a drive-by shooting, holding (1) the State did not present sufficient evidence to support Defendant's conviction because Defendant's conduct in this case did not meet the definition of a drive-by shooting; and (2) the district court did not err when it admitted testimony at trial that a witness was threatened and attacked for being a "snitch." Remanded with instructions to enter a judgment of conviction on the second-degree intentional murder count. View "State v. Hayes" on Justia Law

After a jury trial, Appellant was convicted of possessing a firearm as an ineligible person in violation of Minn. Stat. 624.713(1)(2), which prohibits a person previously convicted of a crime of violence from possessing a firearm. After trial, Appellant unsuccessfully moved to vacate his conviction on the basis that the statute, as applied to him, violated the Second Amendment. The court of appeals upheld the statute as constitutional and affirmed Appellant's conviction. The Supreme Court affirmed, albeit on different grounds, holding that application of section 624.713(1)(2) to Appellant did not violate the Second Amendment as historically understood, because the Second Amendment as understood at the time of its ratification excluded those convicted of crimes of violence from exercising the right to possess a firearm. View "State v. Craig" on Justia Law