Justia Minnesota Supreme Court Opinion Summaries

After a jury trial, Appellant was convicted of aiding and abetting the first-degree murder of his brother as well as obstructing an investigation. Appellant was sentenced to life in prison without the possibility for parole. Appellant subsequently filed a petition for postconviction relief, which the postconviction court denied. The Supreme Court affirmed, holding (1) Appellant's ineffective-assistance-of-counsel claim failed because Appellant failed to show that, but for his attorneys' alleged errors, there was a reasonable probability the outcome of his trial would have been different; and (2) any error in the admission of statements made by Appellant's sister and girlfriend was harmless beyond a reasonable doubt. View "Hawes v. State" on Justia Law

Following a jury trial, Appellant was convicted of first-degree premeditated murder and attempted first-degree premeditated murder. After Appellant's first petition for postconviction relief was denied, Appellant filed a second postconviction petition. After a hearing, the postconviction court denied Appellant's petition. Appellant appealed, contending (1) the postconviction court erred in concluding that an affidavit from a recanting witness is inadmissible hearsay, and (2) he was denied the effective assistance of counsel during the postconviction proceedings. The Supreme Court affirmed, holding (1) the postconviction court did not abuse its discretion in excluding the affidavit, as Appellant failed to establish corroborating circumstances clearly indicating the trustworthiness of Appellant's affidavit; and (2) Appellant did not have a constitutional right to effective assistance of postconviction counsel, and therefore, his ineffective-assistance-of-counsel claim failed as a matter of law. View "Ferguson v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree premeditated murder and attempted first-degree murder. Defendant was sentenced to life imprisonment. The Supreme Court affirmed Defendant's convictions on direct appeal. Defendant filed a petition for habeas corpus relief in federal district court, which was denied, and a petition for postconviction relief in state court, which was also denied. Defendant subsequently filed a second petition for postconviction relief, which the postconviction court denied after concluding that the petition was filed after the expiration of the two-year limitations period in Minn. Stat. 590.01, subd. 4(a)(2). The Supreme Court affirmed, holding that the district court did not abuse its discretion in denying the petition as untimely, as the petition satisfied neither exception to the limitations period. View "Berkovitz v. State" on Justia Law

After a jury trial, Appellant was convicted of aiding and abetting first-degree premeditated murder and sentenced to life in prison without the possibility of release. The Supreme Court affirmed Appellant's conviction and sentence. Appellant subsequently filed a petition for postconviction relief alleging seven claims. The postconviction court summarily denied the petition without a hearing. The Supreme Court affirmed in part, reversed in part, and remanded, holding (1) the postconviction court erred in denying Appellant's request for an evidentiary hearing on his claim of witness recantation; but (2) the postconviction court did not err in finding Appellant's ineffective-assistance-of-counsel claim to be without merit and in concluding that Appellant's remaining claims were barred by State v. Knaffla. View "Martin v. State" on Justia Law

Appellant, an enrolled member of the Leech Lake Band of Ojibwe, was civilly committed to the Minnesota Sex Offender Program (MSOP). Appellant appealed, challenging his indeterminate civil commitment by asserting three substantive claims. The Supreme Court affirmed, holding (1) the district court had jurisdiction to indeterminately civilly commit an enrolled member of the Leech Lake Band of Ojibwe; (2) the doctrines of collateral estoppel and res judicata did not preclude the State from presenting in the civil commitment proceeding evidence of conduct alleged in earlier criminal cases that ended in acquittals; and (3) Appellant waived his to right appellate review of his claim that the State violated the Minnesota Constitution when it committed him without a trial by jury. View "Beaulieu v. Dep't of Human Servs." on Justia Law

Appellant was convicted of aiding and abetting first-degree murder and aiding and abetting attempted first-degree murder. Appellant appealed, arguing that the district court committed reversible error in admitting a statement she made to police as the fruit of an unlawful arrest in violation of the Fourth Amendment. The Supreme Court affirmed, holding (1) the trial court erred in admitting Appellant's statement to police because the taint of Appellant's unlawful arrest was not purged at the time Appellant made her statement, and therefore, the statement was inadmissible; but (2) the trial court's error in admitting this statement was harmless beyond a reasonable doubt. View "State v. McDonald-Richards" on Justia Law

This case arose out of three biting incidents involving a dog owned by Respondent. After the first bite, the City of Lino Lakes designated Respondent's dog as "potentially dangerous," and after the second bite, the City designated the dog as "dangerous." After the third bite, the City ordered the dog to be destroyed. The court of appeals reversed the City's decisions, holding that Appellant's inability to challenge the "potentially dangerous" designation violated his right to procedural due process. The Supreme Court reversed the decision of the court of appeals, upheld the City's designation of the dog as "dangerous," and affirmed the City's order to destroy the dog, holding (1) Respondent was not constitutionally entitled to a hearing to challenge the "potentially dangerous" designation; and (2) substantial evidence supported the City's decisions. View "Sawh v. City of Lino Lakes" on Justia Law

A jury found Appellant guilty of first-degree premeditated murder and second-degree intentional murder. The Supreme Court affirmed, holding that the district court did not err in (1) denying Appellant's motion to suppress his statement to police, as Appellant was not in custody or under arrest when the statement was made; (2) refusing to instruct the jury that Appellant's girlfriend, H.J., was an accomplice as a matter of law, as the issue of whether H.J. was an accomplice was a fact question for the jury; (3) failing to instruct the jury on the aiding-and-advising theory of accomplice liability; and (4) admitting evidence of Appellant's prior assaults of H.J. View "State v. Scruggs" on Justia Law

Appellant was charged with first- and third-degree on the ground that Appellant injured a young child in his care. A jury found Appellant not guilty of both charges, and the district court entered a judgment of acquittal. Appellant then petitioned the district court for an order sealing the criminal records related to the alleged assault. The district court granted Appellant's petition, concluding that the State failed to prove by clear and convincing evidence that the public's interests outweighed Appellant's interests pursuant to Minnesota's expungement statute. The court of appeals reversed, finding that Appellant proved no specific disadvantage to himself against which to balance the interests of the public. The Supreme Court reversed the decision of the court of appeals, holding that an expungement petitioner is not required to prove specific disadvantages he or she will suffer if the petition is denied and may instead satisfy his or her burden of production simply by establishing the fact of his or her acquittal. View "State v. R.H.B." on Justia Law

Appellant pled guilty to first-degree murder while committing domestic abuse and was sentenced to life imprisonment with the possibility of parole. Defendant did not appeal but subsequently filed a postconviction petition, alleging that his guilty plea was invalid because it lacked a proper factual foundation. The postconviction court denied relief on the ground that the petition was untimely and lacked substantive merit. The Supreme Court affirmed, holding (1) because there was sufficient evidence of a past pattern of domestic abuse and sufficient evidence of an extreme indifference to human life, Appellant's claim that he was entitled to withdraw his plea failed on the merits, and therefore, Appellant failed to establish a manifest injustice entitling him to withdraw his guilty plea; and (2) therefore, the Court did not need to reach the remaining issues raised in this appeal. View "Lussier v. State" on Justia Law