Articles Posted in Constitutional 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

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The Supreme Court affirmed the postconviction court’s denial of Petitioner’s petition for postconviction relief, holding that the postconviction court did not abuse its discretion. Petitioner was found guilty of first-degree premeditated murder and first-degree felony murder. Petitioner was sentenced to life imprisonment without the possibility of release for the murder conviction. The Supreme Court affirmed. Petitioner later filed a petition for postconviction relief, alleging six grounds for postconviction relief. The postconviction court rejected the petition without holding an evidentiary hearing. The Supreme Court affirmed, holding that Petitioner’s claims were either procedurally barred or failed as a matter of law. View "Fox v. State" on Justia Law

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The legislative amendments to the State Auditor’s responsibilities over audits of Minnesota counties do not violate either the Separation of Powers Clause, Minn. Const. art. III, 1 or the Single Subject Clause, Minn. Const. art. IV, 17. In 2015, a new statute was enacted that governed the State Auditor’s county-audit responsibilities. The statute allowed counties to choose to have the required audit performed by either a Certified Public Accounting (CPA) firm or the State Auditor. The State Auditor brought this suit arguing that the statute violated the Minnesota Constitution. The district court concluded that the legislative modification of the State Auditor’s duties was constitutional. The court of appeals affirmed. The Supreme Court affirmed, holding that the State’s Auditor’s challenges under the Separation of Powers Clause and the Single Subject Clause failed. View "Otto v. Wright County" on Justia Law

Posted in: Constitutional Law

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The Supreme Court affirmed a postconviction order that summarily denied Appellant’s public-trial claim on the grounds that the claim was barred by the rule announced in State v. Knaffla, 243 N.W.2d 737 (Minn. 1976). Appellant was convicted of one count of first-degree murder and two counts of attempted first-degree murder. During trial, the district court required spectators to present photographic identification before entering the courtroom. In his petition for postconviction relief Appellant asserted that the photographic-identification rule denied him his right to a public trial provided by the federal and state constitutions and that his appellate counsel was ineffective for not seeking a stay to expand the record regarding the courtroom “closure.” Relying on the rule announced in Knaffla, the postconvcition court summarily denied the petition for postconviction relief. The Supreme Court affirmed, holding (1) because Appellant’s public-trial claim was raised by Appellant and rejected by the Supreme Court on direct appeal, the postconviction court properly concluded that Knaffla barred the claim; and (2) Appellant forfeited appellate review of his argument that the interests-of-justice exception applied in his case. View "Taylor v. State" on Justia Law

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Law enforcement officers did not violate Defendant’s Fifth Amendment privilege against self-incrimination when, after Defendant invoked his privilege against self-incrimination, they later asked him if he was willing to sign a written consent to the taking of a DNA sample and explained to him why they sought the sample. Defendant was charged with possession of a firearm by an ineligible person and possession of a short-barreled shotgun. Defendant filed a motion to suppress DNA evidence and his admission that he had handled the shotgun, claiming that the officers conducted a second custodial interrogation after he had invoked his privilege against self-incrimination. The district court denied the motion. The Supreme Court affirmed, holding that the officers did not violate Defendant’s constitutional privilege against self-incrimination because, although Defendant’s statements that he had already handled the shotgun were incriminating testimonial communications, none of the officers’ actions were reasonably likely to elicit an incriminating testimonial communication. Therefore, a Miranda warning was not required. View "State v. Heinonen" on Justia Law

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Failing to register is a continuing crime that includes the entire range of dates on which Defendant failed to register in this case, and a jury was not required to find the date of Defendant’s current offense. Defendant was convicted of knowingly failing to register as a predatory offender. Under the Minnesota Sentencing Guidelines, prior felony sentences are used to calculate criminal history scores unless a period of fifteen years has elapsed between “the date of the current offense” and the expiration of the prior felony sentence (see Minn. Stat. 243.166). Defendant argued that “the date of the current offense” for his crime was the last day the offense occurred and that a jury must decide that date. The court of appeals concluded that “the date of the current offense,” which is a continuing offense, is the first day the offense occurs. The Supreme Court affirmed, holding (1) the district court did not err in including Defendant’s 1996 felony conviction in his criminal history score because fifteen years had not elapsed between the expiration of Defendant’s sentence for his 1996 conviction and the start of his current offense; and (2) Defendant’s sentence did not violate his Sixth Amendment right to a jury trial under Blakely v. Washington, 542 U.S. 296 (2004). View "State v. Washington" on Justia Law

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The warrantless search of Defendant’s property violated Defendant’s Fourth Amendment rights in this case. Here, an officer entered Defendant’s property, examined a stolen camper trailer and then, after obtaining Defendant’s consent, searched Defendant’s home. Defendant filed a motion to suppress, arguing that the officer’s examination of the camper was unconstitutional and tainted his subsequent consent to the search of his home. The district court denied the motion to suppress, concluding that because the camper was on a driveway that was impliedly open to the public, the officer’s entry onto Defendant’s property was lawful and that the officer had authority to seize the camper under the plain-view doctrine. The court of appeals reversed. The Supreme Court affirmed, holding (1) the camper was located on property that was afforded the constitutional protections of the home; and (2) the officer’s conduct was beyond the objectively reasonable scope of any implied license to enter Defendant’s property, and therefore, the warrantless search violated Defendant’s Fourth Amendment rights. View "State v. Chute" on Justia Law

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In this case involving the constitutionality of the Minnesota Unclaimed Property Act the Supreme Court held (1) owners of interest-bearing bank accounts have a constitutionally protected property right that is taken when the State does not compensate the owners for lost interest after transferring and holding unclaimed property under the Act; and (2) the notice provided under the Act to owners of such property valued over $100 is sufficient to satisfy the requirements of due process. Appellants in this case were four property owners whose property was presumed abandoned under the Act and transferred to the State. Appellants alleged that they did not receive sufficient notice that their property had been remitted to the State, in violation of their due process rights, and that the Act effected an unconstitutional taking because they did not receive constructive interest on the unclaimed property after it was delivered to the State. The Supreme Court held that the State was not required to pay interest to some of Appellants in this case because the unclaimed property at issue was not interest bearing and that the notice provided to Appellants under the Act met the requirements of procedural due process. View "Hall v. State" on Justia Law

Posted in: Constitutional Law

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The Fifth Amendment privilege against self-incrimination does not protect a person from being ordered to prove a fingerprint to unlock a seized cellphone. The police lawfully seized a cellphone from Defendant and attempted to execute a valid warrant to search the cellphone, which had a fingerprint-scanner security lock that prevented the search. When Defendant refused to block the cellphone with his fingerprint the district court ordered Defendant to provide his fingerprint so the police could search the cellphone’s contents. The court of appeals affirmed, concluding that providing a fingerprint was not privileged under the Fifth Amendment. The Supreme Court affirmed, holding that because providing the fingerprint elicited only physical evidence from Defendant and did not reveal the contents of his mind, no violation of the Fifth Amendment privilege against self-incrimination occurred. View "State v. Diamond" on Justia Law

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Appellant Emile Rey pleaded guilty to one count of identity theft involving eight or more direct victims. The district court ordered Rey to pay the mandatory-minimum restitution of $1,000 to each of his 66 direct victims, totaling $66,000. Rey appealed, asserting that the mandatory-minimum restitution he was ordered to pay violated his procedural and substantive due process rights and was an unconstitutional fine. The court of appeals affirmed. Rey asked the Minnesota Supreme Court to declare the statute unconstitutional, vacate the restitution order, and remand the matter for a restitution hearing or a Blakely trial. The Court declined, and affirmed the restitution order. View "Minnesota v. Rey" on Justia Law