Justia Minnesota Supreme Court Opinion Summaries

After a jury trial, Brett Borg was found guilty of third-degree criminal sexual conduct. The court of appeals reversed Borg's conviction, concluding that the district court erred when it allowed a police officer to testify in the State's case in chief that Borg did not respond to a mailed request for an interview by the officer. At issue on appeal was whether the Fifth Amendment prohibits the State from eliciting testimony during its case in chief regarding a criminal defendant's lack of response to a letter mailed to him by the police when the defendant was not under arrest or in custody and had not been informed of his Miranda rights. The Supreme Court reversed, holding that the district court did not err when it allowed the testimony because the Fifth Amendment does not prohibit the State from introducing evidence regarding a defendant's silence unless the government compelled the defendant to speak or to remain silent. View "State v. Borg" on Justia Law

Appellant Thomas Zais was charged, in part, with disorderly conduct. Before trial, Zais moved to exclude the proposed testimony of his wife on the ground that it was barred by the marital privilege. The district court concluded that the crime exception to the marital privilege did not apply to the charged offense of disorderly conduct, and therefore Zais's wife was barred from testifying against Zais without his consent. The court of appeals reversed and remanded. The Supreme Court affirmed, holding that Zais's wife could testify against Zais on the disorderly conduct charge because (1) the crime exception to the marital privilege applies to the charged offense of disorderly conduct when the alleged conduct is committed by one spouse against the other spouse; and (2) because the conduct underlying Zais's charged offense was directed at his wife, the crime exception to the marital privilege applied in this case. View "State v. Zais" on Justia Law

Appellant Erik Jeffries pled guilty to felony domestic assault and negotiated an agreement with the State in which he would receive a stayed sentence. The district court indicated at the plea hearing that it was accepting Jeffries' plea and that Jeffries was convicted. At a later date, the court told Jeffries it was "giving you your pleas back" and set the case for trial. Jeffries subsequently reached another plea agreement with the State that resulted in a sixty-month executed sentence. Jeffries appealed, arguing that the Double Jeopardy Clause prohibited the State from prosecuting him a second time for felony domestic assault. The court of appeals affirmed the sentence. The Supreme Court reversed and vacated Jeffries' second conviction, holding (1) the district court unconditionally accepted Jeffries' first guilty plea, (2) the guilty plea was recorded as required by statute by its inclusion in the record of the plea hearing, (3) the second prosecution for the same offense violated the Double Jeopardy Clause, and (4) Jeffries did not forfeit his double-jeopardy claim by entering a second guilty plea. Remanded for resentencing on Jeffries' first conviction. View "State v. Jeffries" on Justia Law

Appellant Calvin Ferguson was convicted of first-degree premeditated murder and sentenced to life in prison without any possibility of parole. On appeal, the Supreme Court reversed, holding that the district court erred when it excluded evidence that had an inherent tendency to connect an alternative perpetrator to the shooting of the victim because (1) the evidence showed that the alternative perpetrator's physical description was in several ways similar to the description of the shooter, (2) the alternative perpetrator's vehicle matched the description of the shooter's vehicle, (3) the alternative perpetrator's nickname matched that of the shooter, and (4) the alternative perpetrator had a connection with the victim. Because the district court's exclusion of the alternative perpetrator evidence denied Ferguson his constitutional right to present a complete defense and the court's error was not harmless beyond a reasonable doubt, the case was remanded for a new trial. View "State v. Ferguson" on Justia Law

Appellant Mahdi Ali was indicted for murder in the first degree and murder in the second degree for the shooting deaths of three individuals. The indictment alleged that Ali was seventeen years old on the date of the alleged offenses and therefore automatically subject to trial in the district court. Ali moved to dismiss the indictment, contending that he was fifteen years old on the date of the shootings and that the jurisdiction of the juvenile court was therefore exclusive. The district court denied the motion, concluding that Ali had reached his sixteenth birthday before the date of the shootings. The court of appeals dismissed Ali's appeal, concluding that the district court's order denying Ali's motion to dismiss the indictment was not appealable. The Supreme Court reversed in part and affirmed in part, holding (1) the denial of a defendant's motion to dismiss an indictment for murder for lack of subject matter jurisdiction is immediately appealable as of right; and (2) when the age of the defendant determines the jurisdiction of the court, the State has the burden of proving, by a preponderance of the evidence, the defendant's age on the date of the alleged offense. View "State v. Ali" on Justia Law

Following a bench trial, Keonne Palmer was found guilty of first-degree premeditated murder, second-degree intentional murder, and possession of a firearm by a prohibited person. Palmer appealed. The Supreme Court affirmed, holding (1) the circumstantial evidence in this case led to the conclusion that Palmer considered, planned, and prepared for the victim's death, and therefore, the evidence was sufficient to support a conviction of premeditated murder; (2) any failure by the district court to consider lesser-included manslaughter offenses could not have affected Palmer's substantial rights because the inclusion of manslaughter charges would not have affected the outcome; and (3) the trial court did not improperly pronounce Palmer's sentence. View "State v. Palmer" on Justia Law

After a jury trial, Brett Borg was found guilty of third-degree criminal sexual conduct. During the trial, the district court allowed a police officer to testify in the State's case in chief that Borg did not respond to a request for an interview by the officer. The court of appeals reversed Borg's conviction, concluding that the district court erred when it allowed the officer to testify about "silence in response to police questions or attempts to pose questions." The Supreme Court reversed the court of appeals and affirmed Borg's conviction, holding that the Fifth Amendment does not prohibit the State from introducing evidence during the State's case in chief regarding a defendant's silence unless the government compelled the defendant to speak or remain silent. View "State v. Borg" on Justia Law

William Jacobs was charged with two counts of criminal sexual conduct. Jacobs moved to remove the judge assigned to his case for cause, basing his motion on the fact that the judge had not disclosed that his spouse was, at the time, an attorney with the county attorney's office that was prosecuting the case. Jacobs' motion was denied. The court of appeals denied Jacobs' writ of prohibition, holding that a spouse's position as an assistant county attorney in the public office that is prosecuting the case does not by itself create an appearance of partiality. The Supreme Court affirmed, holding that the judge was not required to disqualify himself from the case because a reasonable examiner, with full knowledge of the facts and circumstances in this case, would not question the judge's impartiality. View "State v. Jacobs" on Justia Law

Following a jury trial, Lawrence Montanaro was convicted of first-degree murder of a police officer. After the statute of limitations for filing a postconviction petition expired, Montanaro filed a petition for postconviction relief. The postconviction court denied the petition without deciding whether Montanaro established an exception to the statute of limitations. The Supreme Court affirmed, holding that the postconviction court did not abuse its discretion in denying Montanaro's request for a new trial based on the court's conclusion that alleged errors in the jury instructions and the prosecutor's alleged misconduct during his closing argument did not satisfy the third prong of the plain error test because the errors did not affect Montanaro's substantial rights. View "Montanaro v. State" on Justia Law

Appellant Victor Martinez-Mendoza was charged by complaint with one count of first-degree criminal sexual conduct and one count of second-degree criminal sexual conduct. The State and Appellant reached a plea agreement in which Appellant would plead guilty to count two of the complaint and count one would be dismissed. Appellant subsequently pleaded guilty to count two, and the district court adjudged Appellant guilty of count two. Before the sentencing hearing, the State learned that the actual presumptive guidelines sentence for the count two offense involved a much shorter incarceration time than the parties had originally thought. The State moved to vacate the plea or, in the alternative, reinstate count one of the complaint. The district court denied the motion, citing double jeopardy concerns. The court of appeals reversed based on the parties' mutual mistake. The Supreme Court reversed, holding that jeopardy attached when the trial court accepted and recorded Appellant's guilty plea, and thus, any appeal by the State was barred as moot as a matter of law. View "State v. Martinez-Mendoza" on Justia Law