Justia Minnesota Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the district court summarily denying Appellant's claims for postconviction relief, holding that the district court did not abuse its discretion.After a jury trial, Defendant was convicted of first-degree premeditated murder as a principal and as an aider and abettor and sentenced to life in prison without the possibility of release. Defendant later moved for postconviction relief, alleging that the State committed Brady violations during his criminal trial and other grounds for relief. The district court denied Defendant's petition for postconviction relief without holding an evidentiary hearing. The Supreme Court affirmed, holding that Defendant was not entitled to relief on his claims for postconviction relief. View "Thoresen v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of first-degree criminal sexual conduct, holding that the modified plain error doctrine was not satisfied in this case.On appeal, Defendant argued that a statement made by the prosecutor during his jury trial required reversal of his conviction and a new trial. At issue was the prosecutor's statement to the jury during closing argument that a unanimous verdict on one element of the offense - specifically, whether Defendant acted with force or with coercion to accomplish the act of sexual penetration - was not required. The court of appeals affirmed, holding (1) the phrase "force or coercion in Minn. Stat. 609.342(a)(e)(i) sets forth alternative means for completing the sexual penetration element of the offense; and (2) therefore, a unanimous jury verdict on whether Defendant used force or coercion was not necessary. The Supreme Court affirmed, holding that no relief was warranted in this case. View "State v. Epps" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the decision of the district court granting Defendant's motion to suppress his statements to his probation officer and a polygraph administrator about his criminal conduct, holding that suppression of the statements was not required.Specifically, the Supreme Court held (1) Defendant made the statements at issue without invoking his constitutional privilege against self-incrimination, and the penalty exception to the general rule that a person cannot assert the privilege against self-incrimination without first invoking the privilege did not apply; (2) the portion of Minn. Stat. 634.03 requiring exclusion of confessions "made under the influence of fear produced by threats" excludes confessions made under circumstances where the inducement to speak was such that there was a fair risk that the confession was false; and (3) exclusion of Defendant's statements was not required in this case. View "State v. McCoy" on Justia Law

The Supreme Court affirmed the judgment of the district court overruling Appellant's objection to the State's peremptory strike of a prospective juror, holding that Appellant did not meet his burden of proving that the State's race-neutral reason for the strike was a pretext for racial discrimination.Appellant was convicted of first- and second-degree criminal sexual conduct. On appeal, Defendant challenged the State's peremptory strike of the only nonwhite person from the jury venire. The court of appeals affirmed, holding that the prosecutor's explanations for striking the venire-person were race-neutral reasons for the peremptory strike. The Supreme Court affirmed, holding that the district court did not err in denying Appellant's Batson challenge to the State's peremptory strike of the juror. View "State v. Lufkins" on Justia Law

The Supreme Court affirmed Defendant's convictions of two counts of first-degree premeditated murder for the deaths of an adult and an infant, holding that the district court erred in failing to suppress Defendant's statement to the police, the error was harmless beyond a reasonable doubt.Specifically, the Supreme Court held (1) Defendant's statement to police should have been suppressed because Defendant unambiguously invoked his constitutional right to remain silent during the police interrogation, but the failure to do so by the district court was harmless beyond a reasonable doubt; (2) the evidence was sufficient to prove that Defendant had an intent to kill when he fired the gunshot that killed the infant; and (3) the district court did not abuse its discretion by imposing consecutive sentences. View "State v. McInnis" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Defendant's pretrial motion to strike down Minn. Stat. 624.714, subd. 1a, the permit-to-carry statute, and convicting Defendant of violating the statute, holding that the permit-to-carry statute does not violate the Second Amendment.Minn. Stat. 624.714, subd. 1a requires individuals to obtain a permit to carry a handgun in public. Defendant was charged with carrying a pistol in a public place without a permit in violation of the statute. Defendant filed a pretrial motion to strike down the permit-to-carry statute, arguing that the requirement that an individual obtain a permit to carry a firearm violates the Second Amendment. The district court denied the motion. The Supreme Court affirmed, holding that the permit-to-carry statute withstands strict scrutiny and does not violate the Second Amendment. View "State v. Hatch" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court finding Defendant guilty of violating a domestic abuse no contact order (DANCO), holding that the State did not violate Defendant's rights under the Minnesota Uniform Mandatory Disposition of Detainers Act (UMDDA).Defendant made a proper request for a final disposition under the UMDDA, and the State dismissed the charges pending against him. Nearly one year later, the State refiled the charges and brought Defendant to trial. The Supreme Court affirmed the resulting conviction, holding (1) once the State dismissed the pending complaint, Defendant no longer enjoyed a right to disposition of that complaint under the UMDDA; (2) the delay between Defendant's speedy trial request and his trial did not violate his constitutional right to a speedy trial; and (3) the district court did not abuse its discretion by declining to dismiss the State's complaint under Minn. R. Crim. P. 30.02. View "State v. Mikell" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's conviction of theft under a principal theory of criminal liability and of being an indelible person in possession of a firearm, holding that the district court erred when it failed to conduct a Confrontation Clause analysis surrounding the testimonial statement of a nontestifying co-conspirator, but the error was harmless.On appeal, Defendant argued that the district court violated his right to confrontation by admitting his co-conspirator's statements to the police when Defendant had no opportunity to cross-examine his co-conspirator. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the district court violated Defendant's right to confrontation when it admitted the disputed statements into evidence at trial; but (2) the violation of the Confrontation Clause was harmless beyond a reasonable doubt. View "State v. Sutter" on Justia Law

The Supreme Court affirmed in part and reversed in part the decision of the court of appeals affirming the decision of the district court granting the Commissioner of Correction's motion to dismiss Plaintiff's action seeking declaratory and injunctive relief, holding that some of the facts alleged in the complaint stated a claim upon which relief could be granted.Defendant pleaded guilty with several crimes. After Defendant began serving his sentence the Commissioner denied his application for the Challenge Incarceration Program on the grounds that persons required to register as predatory offenders are not eligible for that program. Defendant then brought this action alleging that the predatory offender registration statute and some of its collateral consequences denied him due process as applied to his charged, but not convicted, enumerated offense of kidnapping. The court of appeals affirmed. The Supreme Court affirmed in part and reversed in part, holding that the district court erred in dismissing Defendant's claim of substantive and procedural due process violations based on his alleged fundamental right to parent his child. View "Werlich v. Schnell" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction, holding that the State's discovery motion at Defendant's first court appearance seeking to photograph transitory scratches on Defendant's arms was not a critical stage of the criminal proceeding that required the presence of defense counsel.At Defendant's first appearance on criminal sexual conduct charges the State made a discovery motion to take photographs of transitory scratch marks on Defendant's arms. At issue was whether the discovery motion was a critical stage of the proceedings entitling Defendant to have counsel present. The court of appeals concluded that the discovery hearing on the "otherwise-valid" discovery request to noninvasively photograph scratches was not a critical stage of the proceedings. The Supreme Court affirmed, holding that there was no violation of Defendant's Sixth Amendment right to counsel under the circumstances of this case. View "State v. Zaldivar-Proenza" on Justia Law