Justia Minnesota Supreme Court Opinion Summaries

After a jury trial, Appellant Daniel Anderson was convicted of first-degree murder for the death of his girlfriend's nineteen-month-old son. Anderson filed a petition for postconviction relief, arguing that it was error for the State to indict him under the domestic abuse murder statute and that he should have been indicted under what he claimed to be the more specific child abuse murder statute. The postconviction court denied relief without a hearing, reasoning that the claim was Knaffla-barred and that no exception to Knaffla applied. Under State v. Knaffla, a postconviction relief petition raising claims that were raised on direct appeal or that were known or should have been known but were not raised by the petition at the time of direct appeal is procedurally barred. The Supreme Court affirmed, holding that the postconviction court properly concluded that Anderson's claim was Knaffla-barred and that Anderson's petition was not saved by either exception to the Knaffla bar, as his claim was not novel and the interests of fairness and justice did not warrant consideration of his claim. View "Anderson v. State" on Justia Law

Appellant was convicted on six controlled substance crimes. The court of appeals affirmed Brist's convictions but remanded for the district court to modify Brist's sentence. On appeal, Brist argued that the admission of an audio recording of a statement made by her nontestifying coconspirator to a confidential government informant during a drug transaction violated her rights under the Confrontation Clause. The Supreme Court affirmed Brist's convictions, concluding that it was bound by Bourjaily v. U.S., which held that recorded statements of a nontestifying coconspirator, otherwise admissible as nonhearsay under materially identical evidentiary rules, are admissible at trial against another coconspirator without violating the Confrontation Clause. Therefore, the district court's admission into evidence of the coconspirator's statements in this case did not violate Brist's rights under the Confrontation Clause. View "State v. Brist" on Justia Law

The State charged Ronald Fleck with second-degree assault after he stabbed his former girlfriend. During the trial, after all the evidence was presented to the jury, the district court submitted two forms of assault to the jurors, (1) assault-fear, prohibiting an act done with the intent to cause fear in another of immediate bodily harm or death, and (2) assault-harm, prohibiting the intentional infliction of bodily harm. The district court instructed the jurors that voluntary intoxication applied to an assault-fear offense but not an assault-harm offense. The jury found Fleck not guilty of second-degree assault-fear but guilty of second-degree assault-harm. The court of appeals reversed, concluding that the district court erred by failing to instruct the jury that voluntary intoxication applied to an assault-harm offense. The Supreme Court reversed the court of appeals' decision and reinstated Fleck's conviction, holding that the district court properly instructed the jury on the applicable law. View "State v. Fleck" on Justia Law

Appellant Herman Tanksley, Jr. was convicted of fourth-degree driving while impaired, which is driving with an alcohol concentration of 0.08 or more. Tanksley appealed, arguing that he was entitled to a Frye-Mack hearing on the reliability of first-void urine testing to resolve his claim that first-void urine testing does not reliably correlate with a driver's blood alcohol concentration. The court of appeals concluded that the district court abused its discretion in denying the Frye-Mack hearing to Tanksley but that the error was harmless. The Supreme Court granted transfer and affirmed the district court, holding that the district court was not required to hold a Frye-Mack hearing based on Tanksley's challenge, as blood alcohol concentration is irrelevant when the State seeks to prove the offense of driving with an alcohol concentration of 0.08 or more solely with evidence of the amount of alcohol in the defendant's urine. View "State v. Tanksley" on Justia Law

Defendant Randolph Johnson was charged with felony domestic assault and misdemeanor fifth-degree assault. As part of a negotiated plea, Defendant pleaded guilty to an amended charge of misdemeanor domestic assault, and the State dismissed the felony charge. The district court ordered that Defendant submit to a DNA sample pursuant to Minn. stat. 609.117, subd. 1(1), which requires a defendant charged with a felony and then convicted of a misdemeanor arising out of the same set of circumstances to submit a DNA sample for the limited purpose of criminal identification, after concluding that the statute was constitutional as applied to Defendant. The Supreme Court affirmed after applying a totality-of-the-circumstances test, holding (1) the State's legitimate governmental interests in conducting a search of Defendant to collect a biological specimen for criminal identification purposes outweighed Defendants' reduced expectation of privacy following his misdemeanor conviction arising out of the same set of circumstances as his felony charge; (2) consequently, the statute did not violate the prohibitions against unreasonable searches and seizures in the state and federal constitutions; and (3) Defendant's equal protection claim failed. View "State v. Johnson" on Justia Law

Appellant, a juvenile, was petitioned for a felony and then adjudicated delinquent of a misdemeanor arising out of the same set of circumstances. The court ordered that Appellant provide a biological speciman to determine her DNA profile for the limited purpose of criminal identification after concluding that Minn. Stat. 609.117, subd. 1(2), which requires a juvenile adjudicated delinquent of a misdemeanor to submit a DNA sample, did not violate constitutional prohibitions against unreasonable searches and seizures and was not a denial of equal protection. The Supreme Court affirmed after applying a totality-of-the-circumstances test, holding (1) the State's legitimate governmental interests in collecting Appellant's DNA outweighed Appellant's reduced expectation of privacy following her misdemeanor adjudication arising out of the same set of circumstances as her felony petition; (2) consequently, as applied to Appellant, section 609.177, sub. 1(2) did not violate the prohibitions against unreasonable searches and seizures in the state and federal constitutions; and (3) Appellant's equal protection claim failed because Appellant was not similarly situated to misdemeanants without a felony petition, who were not required to provide a DNA sample under the statute. View "In re M.L.M." on Justia Law

Appellant Darryl Colbert was convicted of premeditated first-degree murder. The Supreme Court affirmed Colbert's conviction on direct appeal. Colbert subsequently filed five petitions for postconviction relief, and the postconviction court denied each petition. In this case, Colbert appealed the postconviction court's denial of his fifth petition for postconviction relief. The Supreme Court affirmed, holding that Colbert's petition was time-barred under Minn. Stat. 590.01, subd. 4, which states that a person seeking relief has two years from the disposition of the person's direct appeal to file a petition for postconviction relief, because it was filed more than two years after it arose. View "Colbert v. State" on Justia Law

Michael Ferguson was convicted of one count of felony drive-by shooting at an occupied building and eight counts of second-degree assault, arising out of an incident in which multiple shots were fired at a duplex occupied by eight people. After Ferguson successfully appealed his original sentence, the district court imposed sentence on the drive-by shooting conviction and all eight assault convictions. On appeal, the court of appeals held that Minn. Stat. 609.035 required the district court to sentence Ferguson only on the drive-by shooting at an occupied building conviction. The Supreme Court reversed the court of appeals and upheld the sentence imposed by the district court, holding that the court of appeals misapplied the rule that a district court may not sentence a defendant to more than one crime for each victim, and that a single sentence for drive-by shooting at an occupied building was not commensurate with Ferguson's culpability for using a dangerous weapon to intentionally cause eight persons to fear immediately bodily harm. View "State v. Ferguson" on Justia Law

Appellant Gary Roby was convicted of aiding and abetting the crimes of first-degree premeditated murder, first-degree murder while committing aggravated robbery, and second-degree intentional murder. The Supreme Court affirmed Roby's conviction on appeal. Roby subsequently filed this, his third petition for postconviction relief, arguing that newly discovered evidence should be considered in the interests of justice. The postconviction court denied Roby's petition without an evidentiary hearing, holding (1) Roby's claims that were based on a 1989 police report and a 2002 letter were time-barred, and (2) Roby's remaining claims failed on the merits. The Supreme Court affirmed, holding (1) all of Roby's claims were time-barred under the postconviction statute, and (2) Roby was not entitled to relief through application of the doctrine of equitable tolling. View "Roby v. State" on Justia Law

Appellant Brent Kuhlmann was convicted after a jury trial of domestic assault and test refusal. On appeal, Appellant argued that the trial court committed reversible error when it accepted a stipulation on elements of the charged offenses without advising him of his right to a jury trial on these elements and securing, either in writing or on the record, his personal waiver of the right to a jury trial on the stipulated elements. The court of appeals affirmed Appellant's convictions. The Supreme Court affirmed, holding (1) the trial court erred in failing to obtain Appellant's personal waiver of the right to a jury trial on the previous-conviction elements of the charged offenses; (2) the trial court's failure to obtain Appellant's personal waiver of his right to a jury trial did not amount to structural error; and (3) under the plain error standard, the error did not affect Appellant's substantial rights or the outcome of the case. View "State v. Kuhlmann" on Justia Law