Justia Minnesota Supreme Court Opinion Summaries

After a jury trial, appellant Justin Buckingham was convicted of attempted first-degree premeditated murder and attempted first-degree drive-by-shooting murder. The Supreme Court affirmed appellant's convictions but modified his sentence. Appellant subsequently filed a petition for postconviction relief, asserting that the district court admitted his statements to police in violation of his constitutional rights, his court-ordered psychological evaluation was incomplete, the district court gave the jury an erroneous accomplice liability instruction, and his trial counsel was ineffective. The district court denied Buckingham's petition for relief without a hearing, rejected Buckingham's claims on the merits, and held that most of Buckingham's claims were procedurally barred under State v. Knaffla. The Supreme Court affirmed, holding the district court did not abuse its discretion when (1) it held that Buckingham's claims were barred under Knaffla, and (2) it denied appellant an evidentiary hearing because the records of the proceeding conclusively showed that Buckingham was not entitled to postconviction relief. View "Buckingham v. State" on Justia Law

Diane Cox was charged with issuing dishonored checks with a value of more than $500 in violation of the dishonored-check statute, which is a felony. Cox filed a motion to dismiss, arguing that the sentencing disparity between the dishonored-check statute and the theft-by-check statute violated her constitutional right to equal protection of the law because issuing a dishonored check is a lesser-included offense of theft-by-check yet is punished more harshly than the greater offense. The district court denied Cox's motion but certified to the court of appeals the question of whether the disparity in the severity of punishment between the two statutes, which arguably contemplate the same acts committed under the same circumstances by persons in like situations, constitutes an equal protection violation as applied to defendant and those similarly charged. The appellate court answered the question in the negative. The Supreme Court affirmed, holding that Cox is not similarly situated to a defendant who commits theft by check because her conduct would not support a conviction for theft by check, and therefore Cox was not denied equal protection of the law. View "State v. Cox" on Justia Law

In district court, appellant was convicted of aiding and abetting first-degree premeditated murder. At issue was whether the district court erred when it denied appellantâs pretrial motion to suppress statements made to law enforcement officials after appellant allegedly invoked his state and federal constitutional rights to remain silent and to have counsel present during custodial interrogation. The Supreme Court affirmed, holding (1) an invocation of the right to remain silent is ambiguous if the suspectâs statement could be interpreted as either a general refusal to answer any questions or as an expression of unwillingness to discuss a specific topic, and (2) when a suspect makes an equivocal invocation of the right to counsel, providing the suspect with a Miranda warning is sufficient as a matter of law to satisfy Minnesotaâs âstop and clarifyâ rule.