Articles Posted in Constitutional Law

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The Supreme Court affirmed the decision of the court of appeals affirming the decision of the postconviction court that Defendant was entitled to a new trial because a juror was actually biased and not sufficiently rehabilitated but that the search of Defendant did not violate his Fourth Amendment rights. Defendant was convicted of possession of a firearm by an ineligible person. Thereafter, Defendant filed a postconviction petition arguing that the district court erred in denying his for-cause strike of Juror 18 and that the police unreasonably searched and seized him, violating his Fourth Amendment rights. The postconviction court rejected Defendant’s Fourth Amendment argument but concluded that the district court committed reversible error by denying the motion to strike Juror 18 for cause. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the search of Defendant was objectively reasonable under the emergency-aid exception to the Fourth Amendment warrant requirement; and (2) Defendant was entitled to a new trial because the presence of the actually biased juror. View "Ries v. State" on Justia Law

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The Supreme Court held that the decision of the United States Supreme Court in Birchfield v. North Dakota, 579 U.S. __ (2016), and this Court’s decisions in State v. Trahan, 886 N.W.2d 216 (Minn. 2016), and State v. Thompson, 886 N.W.2d 224 (Minn. 2016), announced a new rule of constitutional law that applies retroactively to cases on collateral view. In this consolidated appeal arising from two separate traffic stops, the Supreme Court reviewed the decision of the court of appeals concluding that the Birchfield rule did not apply retroactively to Defendant’s final convictions because the rule was procedural in nature, and that, therefore, the district courts properly denied Defendant’s postconviction petitions. The Supreme Court reversed and remanded to the district court for further proceedings, holding that the Birchfield rule is substantive and applies retroactively to Defendant’s convictions on collateral review. View "Johnson v. State" on Justia Law

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The Supreme Court held that Minnesota’s Legend Drug Tax, Minn. Stat. 295.52(4), applies to a non-resident pharmacy’s delivery of prescription drugs to Minnesota-based patients and doctors and that such application does not violate the Due Process Clause or Commerce Clause of the United States Constitution. Respondent-pharmacy requested funds from the Department of Revenue for taxes paid under the Legend Drug Tax on transactions between Respondent’s non-resident pharmacies and Minnesota-based patients and doctors. The Commissioner of Revenue denied the refunds. The Tax Court granted summary judgment for Respondent, concluding that the Legend Drug Tax did not apply to the transactions at issue. The Supreme Court reversed, holding that the tax did apply to the transactions and that application of the tax comported with the Due Process and Commerce Clauses of the United States Constitution. View "Walgreens Specialty Pharmacy, LLC v. Commissioner of Revenue" on Justia Law

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The Supreme Court held that a warrantless narcotics-dog sniff in the hallway outside Defendant’s apartment did not violate Defendant’s right to be free from unreasonable searches under the Minnesota and United States Constitutions. A jury found Defendant guilty of first-degree and fifth-degree possession of a controlled substance and possession of a firearm by a prohibited person. The court of appeals reversed the convictions, concluding that the narcotics-dog sniff in the hallway immediately adjacent to Defendant’s apartment door was a search under the Fourth Amendment because it violated Defendant’s reasonable expectations of privacy and that the warrantless search of Defendant’s home was unreasonable. The Supreme Court reversed, holding (1) the police did not intrude upon the curtilage of Defendant’s apartment or his reasonable expectation of privacy when they conducted the dog sniff, and therefore, no Fourth Amendment search occurred; and (2) because the police were lawfully present in the hallway and had a reasonable suspicion of criminal activity, the dog sniff did not violate Minn. Const. art. I, section 10. View "State v. Edstrom" on Justia Law

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The Supreme Court held that Minn. Stat. 609.344(1)(b) and 609.345(1)(b), which prohibit sexual penetration and sexual conduct where the complainant is between thirteen and sixteen years of age and the actor is more than two years older than the complainant, are constitutional even though they prevented Defendant from asserting a mistake-of-age defense. The statutes at issue provide a mistake-of-age defense but only to actors who are no more than 120 months older than the complainant. On appeal, the court of appeals held that the statutes did not violate the guarantees of substantive due process and equal protection under the federal and state constitutions and did not unconstitutionally impose strict liability. The Supreme Court affirmed, holding (1) sections 2609.344(1)(b) and 609.345(1)(b) do not violate substantive due process or equal protection by limiting a mistake-of-age defense to defendants who are no more than 120 months older than the complainant; and (2) the statutes do not impose strict liability but, instead, require proof beyond a reasonable doubt that the actor had a general intent to engage in sexual penetration or sexual contact with the complainant. View "State v. Holloway" on Justia Law

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The Supreme Court held that separation-of-powers principles do not prevent the judiciary from ruling on whether the Legislature has violated its duty under the Education Clause of the Minnesota Constitution or violated the Equal Protection or Due Process Clauses of the Minnesota Constitution. Appellants brought a putative class-action complaint on behalf of their children, public school students, claiming that the State had violated the Education, Equal Protection, and Due Process Clauses of the Minnesota Constitution. The court of appeals concluded that the claims presented nonjusticiable political questions. The Supreme Court reversed,holding that Appellants’ claims were justiciable. Specifically, the Court held (1) the courts are the appropriate domain for determinations as to whether the Legislature has violated its constitutional duty under the Education Clause; and (2) as to Appellants’ equal protection and due process claims, while the Legislature plays a critical role in education, “it is ultimately the judiciary’s responsibility to determine what our constitution requires and whether the Legislature has fulfilled its constitutional duty.” View "Cruz-Guzman v. State" on Justia Law

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The Supreme Court affirmed Appellant’s conviction for first- and second-degree murder on an aiding-and-abetting theory. The Court held (1) even if it was error for the district court to admit into evidence Appellant’s statement to police, the error was harmless beyond a reasonable doubt; (2) the district court plainly erred by giving a no-adverse-inference instruction to the jury without Appellant’s consent, but the error was not prejudicial; and (3) assuming, without deciding, that the prosecutor committed misconduct during closing argument by “indirectly alluding” to Appellant’s failure to testify, the prosecutor’s argument was not prejudicial. View "State v. Johnson" on Justia Law

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The Supreme Court held that four irrevocable inter vivos trusts (the Trusts) lacked sufficient relevant contacts with Minnesota during the relevant tax year to be permissibly taxed, consistent with due process, on all sources of income as “resident trusts.” The Trusts filed their 2014 Minnesota income tax returns under protest, asserting that Minn. Stat. 290.01(7b)(a)(2), the statute classifying them as resident trusts, was unconstitutional as applied to them. The Trusts sought refunds for the difference between taxation as resident trusts and taxation as non-resident trusts. The Commissioner of Revenue denied the refund claims. The Minnesota Tax Court granted summary judgment for the Trusts, holding that the statutory definition of “resident trust” violates the Due Process Clauses of the Minnesota and United States Constitutions as applied to the Trusts. The Supreme Court affirmed, holding that, for due process purposes, the State lacked sufficient contacts with the Trusts to support taxation of the Trusts’ entire income as residents. View "Fielding v. Commissioner of Revenue" on Justia Law

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The Supreme Court affirmed the decision of the Minnesota Tax Court affirming the order of the Commissioner of Revenue that assessed Terrance Sargent’s income tax liability for tax years 2010-2014, holding that Sargent’s arguments on appeal were without merit. On appeal, Sargent argued that Minnesota’s income tax violates the Minnesota Constitution and the United States Constitution on several grounds. The Supreme Court affirmed the Minnesota Tax Court's decision after considering all of Sargent’s arguments, holding that they each were without merit. View "Sargent v. Commissioner of Revenue" on Justia Law

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The Supreme Court affirmed in part and reversed and remanded in part the postconviction court’s denial of Petitioner’s second petition for postconviction relief without holding an evidentiary hearing. Petitioner was found guilty of first-degree premeditated murder and sentenced to life in prison without the possibility of release. After his first postconviction petition was summarily denied, Petitioner filed his second postconviction petition, alleging the existence of sixteen pieces of newly discovered evidence. The postconviction court denied the second petition without holding an evidentiary hearing, concluding that the petition was untimely because the facts alleged in the petition did not satisfy the statutory newly-discovered-evidence exception. The Supreme Court reversed in part, holding (1) the postconviction court abused its discretion by making improper credibility determinations without holding an evidentiary hearing; and (2) the facts alleged in support of Petitioner’s remaining claims did not satisfy the newly-discovered-evidence or interests-of-justice exceptions to the two-year statute of limitations. View "Anderson v. State" on Justia Law