Justia Minnesota Supreme Court Opinion Summaries

Appellant was found guilty by a jury of first-degree murder while committing malicious punishment of a child with a past pattern of child abuse for the death of his seventeen-month-old stepson. The supreme Court affirmed Appellant's conviction, holding (1) the district court did not abuse its discretion or violate Appellant's right to present an alternative perpetrator defense in limiting access to social services records; (2) the district court did not err in ruling that potential reverse-Spreigl evidence was inadmissible or violate Defendant's right to present an alternative perpetrator defense in doing so; (3) the State presented sufficient evidence to prove the element of a past pattern of child abuse beyond a reasonable doubt; (4) the jury instructions on the element of a past pattern of child abuse fairly and correctly stated the applicable law; and (5) Defendant's defense counsel did not engage in ineffective assistance of counsel by failing to object to the jury instructions, as the jury instructions given were not erroneous. View "State v. Hokanson" on Justia Law

Following a jury trial, Appellant was convicted of first-degree felony murder, attempted second-degree criminal sexual conduct, and second-degree assault. The Supreme Court affirmed the convictions. Fourteen years later, Appellant filed his second petition for postconviction relief, which the postconviction court summarily denied as untimely filed. Appellant appealed, contending that his petition should be considered because it was not frivolous and was in the interests of justice pursuant to Minn. Stat. 590.01, 4(b) The Supreme Court affirmed, holding that Appellant's postconviction claims were time-barred under section 590.01, 4, and that Appellant's petition failed to satisfy the interests-of-justice exception in Minn. Stat. 590.01, 4(b)(5) because each of the claims in the petition was frivolous. View "Wallace v. State" on Justia Law

After a jury trial, Defendant was convicted of one count of first-degree felony murder and one count of attempted first-degree felony murder. The Supreme Court affirmed Defendant's convictions, holding (1) the district court did not err by refusing to suppress shell casings seized from the back stairway of Defendant's multifamily residence, as their seizure satisfied the plain-view exception to the presumptive rule against warrantless seizures; (2) the State did not commit prosecutorial misconduct when it referenced shell casings found in Defendant's truck; (3) the district court plainly erred when it failed to instruct the jury that, in order to find Defendant guilty of attempted first-degree felony murder, the jury had to find Defendant intentionally aided his alleged accomplices in the commission of the crime, but this error did not warrant the grant of a new trial. View "State v. Milton" on Justia Law

After a jury trial, Defendant was convicted of first-degree felony murder, second-degree intentional murder, and being a prohibited person in possession of a firearm for the shooting death of a cab driver. The district court sentenced Defendant to life imprisonment on the first-degree felony murder conviction and to a sixty-month concurrent sentence on the firearm conviction but did not sentence Defendant on the second-degree intentional murder conviction. The Supreme Court vacated Defendant's second-degree intentional murder conviction but otherwise affirmed Defendant's convictions, holding (1) the district court did not err when it declined Defendant's request for a jury instruction on accomplice testimony; (2) the district court did not abuse its discretion when it instructed the jury to continue deliberating after the jury indicated it was deadlocked; and (3) the district court erred by convicting Defendant of both first- and second-degree murder because second-degree intentional murder is a lesser-included offense of first-degree murder. View "State v. Cox " on Justia Law

Appellant was convicted of aiding and abetting first-degree felony murder. The district court sentenced Appellant to life in prison. On appeal, Appellant claimed that numerous errors entitled him to a new trial. The Supreme Court affirmed Appellant's conviction, holding (1) the jury's verdict was unattributable to any error in admitting Appellant's statement recorded after he allegedly invoked his right to remain silent, and therefore, the admission of the statement into evidence was harmless; (2) the district court did not plainly err by allowing fear testimony at trial; (3) the district court did not abuse its discretion by not admitting certain hearsay statements; (4) the district court did not plainly err by giving a no-adverse-inerence jury instruction without Appellant's clear consent; and (5) Appellant was not entitled to a new trial based on the cumulative effect of the district court's errors. View "State v. Davis" on Justia Law

Appellant was arrested and charged with first-degree premeditated murder. At trial, Appellant admitted shooting the victim, but claimed he did so in self-defense and without premeditation. The jury, rejecting Appellant's self-defense claim, found Appellant guilty of first-degree premeditated murder, and the district court sentenced Appellant to life in prison without the possibility of release. Appellant thereafter filed a petition for postconviction relief, which the postconviction court denied. The Supreme Court affirmed Appellant's conviction and the postconviction court's denial of postconviction relief, holding that each of Appellant's claims was either without merit or did not result in prejudice to Appellant. View "State v. Radke" on Justia Law

Appellant was convicted of first-degree murder while committing a drive-by shooting and drive-by shooting. The Supreme Court affirmed Defendant's conviction. In this case, Defendant appealed the summary denial of his second petition for postconviction relief, which alleged a claim of ineffective assistance of appellate counsel, and his third petition for postconviction relief, which alleged a claim of newly discovered evidence. The Supreme Court (1) affirmed the postconviction court's summary denial of the second postconviction petition because the record conclusively showed appellate counsel was not ineffective; but (2) reversed the court's summary denial of the third postconviction petition and remanded for an evidentiary hearing because the record failed to conclusively show that Appellant was not entitled to relief based on his claim of newly discovered evidence. View "Bobo v. State" on Justia Law

Defendant was found guilty by a jury of three counts of first-degree murder and three counts of second-degree murder. The district court entered convictions on the three counts of first-degree murder and imposed three consecutive life sentences. The Supreme Court affirmed Defendant's convictions on direct appeal. Defendant subsequently filed a second petition for postconviction relief, claiming he was entitled to an evidentiary hearing or a new trial based on newly discovered evidence. Defendant also brought a motion for additional fingerprint and forensic DNA testing. The postconviction court summarily denied the petition without an evidentiary hearing. The Supreme Court affirmed, holding (1) Defendant's petition was time-barred as a matter of law, and (2) the motion was not supported by adequate proof. View "Riley v. State" on Justia Law

A jury found Appellant guilty of first-degree premeditated murder, first-degree murder while committing a kidnapping, second-degree intentional murder, and second-degree felony murder in connection with the stabbing death of his girlfriend. The trial court convicted Appellant of first-degree premeditated murder and sentenced him to life in prison without the possibility of parole. The Supreme Court affirmed Appellant's conviction, holding that, given the evidence of Appellant's planning activity, his motive, and the nature of the victim's killing, and given the reasonable inferences to be drawn from that evidence, the evidence of premeditation was sufficient to support Appellant's first-degree premeditated murder conviction. View "State v. Hurd" on Justia Law

A jury found Defendant guilty of falsely reporting an act of police misconduct under Minn. Stat. 609.505, subd. 2 (the statute) based on the fact that Defendant informed a police officer that another officer forged her signature, knowing that the information conveyed was false. The court of appeals reversed, concluding that the statute was unconstitutional because it criminalizes false speech critical of the police but not false speech that favors the police. The Supreme Court reversed, holding (1) the court of appeals erred in finding the statute unconstitutional because it criminalizes only defamatory speech not protected by the First Amendment and because it was within two of the exceptions to the constitutional prohibition against content discrimination in an unprotected category of speech; but (2) because Defendant's conviction under the statute preceded the Court's narrow construction of the statute, due process considerations entitled her to a new trial. Remanded. View "State v. Crawley" on Justia Law