Justia Minnesota Supreme Court Opinion Summaries

Articles Posted in Constitutional Law
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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

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The Supreme Court reversed the decision of the court of appeals concluding that the United States Supreme Court's decision in Missouri v. McNeely, 569 U.S. 141 (2013), is substantive in the context of a conviction for test refusal, holding that the rule announced in McNeely is procedural and does not apply retroactively to test-refusal convictions on collateral review.In 2010, Defendant was convicted of first-degree test refusal for refusing to submit to a warrantless blood and urine test. In 2016, he filed a petition for postconviction relief, arguing that his conviction was unconstitutional. The district court ultimate determined that Defendant was entitled to postconviction relief, regardless of whether McNeely applied. The court of appeals reversed, holding that McNeely applied retroactively. The Supreme Court reversed and remanded the case, holding that McNeely did not apply retroactively to Defendant's test-refusal conviction, and the district court not properly articulate the pre-McNeely standard for exigent circumstances. View "Johnson v. State" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals affirming the district court's denial of Appellant's petition for postconviction relief after determining that his stay of adjudication and discharge from probation was not a conviction, holding that Appellant's stay of adjudication was not a conviction.Pursuant to a plea agreement, Appellant pleaded guilty to domestic assault-intentional infliction of bodily harm. The district court accepted Appellant's plea of guilty and stayed adjudication under the parties' agreement. After Appellant successfully completed and was discharged from probation he received notice that he was scheduled for immigration removal proceedings. Appellant filed a petition for postconviction relief seeking to withdraw his guilty plea on grounds that he received ineffective assistance of counsel under Padilla v. Kentucky, 559 U.S. 356 (2010). The postconviction court concluded that Appellant had not been convicted of a crime and was therefore not eligible for postconviction relief. The Supreme Court affirmed, holding (1) the plain meaning of the phrase "a person convicted of a crime" in Minn. Stat. 590.01, subd. 1 means a person who has a conviction under Minnesota law; and (2) Appellant's stay of adjudication did not meet this definition. View "Johnston v. State" on Justia Law

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The Supreme Court reversed the decision of the court of appeals reversing the judgment of the district court finding that Minn. Stat. 617.261 was unconstitutional under the First Amendment, holding that the statute does not violate the First Amendment because it survives strict scrutiny.Defendant was charged with a felony-level violation of Minn. Stat. 617.261, the statute that criminalizes the nonconsensual dissemination of private sexual images. Defendant moved to dismiss the charge on constitutional grounds. The district court denied the motion, concluding that the conduct regulated by the statute is entirely unprotected obscene speech and that any degree of overbreadth was insubstantial. The court of appeals reversed, concluding that the statute is unconstitutionally overbroad because it criminalizes a substantial amount of protected speech. The Supreme Court reversed, holding (1) section 617.261 prohibits more than obscenity; but (2) the restriction does not violate the First Amendment because it is justified by a compelling government interest and is narrowly tailored to serve that interest. View "State v. Casillas" on Justia Law

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The Supreme Court affirmed the judgment of the court of appeals concluding that an ordinance adopted by the City of Minneapolis that prohibits certain property owners, property managers, and others from refusing to rent property to prospective tenants in order to avoid the burden of complying with the requirements of Section 8 of the United States Housing Act survives due process and equal protection rational basis scrutiny, holding that the ordinance is constitutional.Plaintiffs, property owners who owned and rented residential properties in the City, alleged, among other things, that the ordinance violated the Due Process Clause and the Equal Protection Clause of the Minnesota Constitution. The district court granted summary judgment in favor of Plaintiffs, concluding that the ordinance violated equal protection and due process protections. The court of appeals reversed on both claims. The Supreme Court affirmed, holding that the Minneapolis ordinance did not violate the Minnesota Constitution's guarantee of substantive due process or equal protection guarantee. View "Fletcher Properties, Inc. v. City of Minneapolis" on Justia Law

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The Supreme Court affirmed the judgment of the district court denying Defendant's petition for postconviction relief arguing that the rule announced in Miller v. Alabama, 567 U.S. 460 (2012), and later clarified in Montgomery v. Louisiana, 577 U.S. __ (2016), should be extended to adult offenders whose crimes reflect the transient immaturity of youth, holding that the district court did not abuse its discretion when it denied Defendant's postconviction petition.Defendant was convicted of first-degree premeditated murder and sentenced to a mandatory term of life in prison without the possibility of release. Defendant was eighteen years and seven days old on the date of the offense. On appeal from the denial of his postconviction motion, Defendant renewed his Miller/Montgomery argument and further asked the Supreme Court to interpret Minn. Const. art. I, 5 to provide greater protection than the Eighth Amendment. The Supreme Court affirmed, holding (1) because the Miller/Montgomery rule is clearly limited to juvenile offenders under the age of eighteen at the time of the offense, the district court did not abuse its discretion when it denied Defendant's petition for postconviction relief; and (2) Defendant forfeited appellate review of his claim under the Minnesota Constitution. View "Nelson v. State" on Justia Law

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The Supreme Court affirmed the judgment of the district court and the court of appeals concluding that Minn. Stat. 609.27 subd. 1(4) was constitutionally overbroad and could not be saved through a narrowing construction or by severing part of it, holding that subdivision 1(4) criminalizes a substantial amount of protected speech and is thus unconstitutional on its face.Defendant was charged with one felony count of attempted coercion under section 609.275, the attempted coercion statute. Defendant filed a motion to dismiss, arguing that the statute was overly broad in violation of the First Amendment. The district court granted the motion to dismiss, and the court of appeals affirmed. The Supreme Court affirmed, holding that Minn. Stat. 609.27 subd. 1(4) is substantially overbroad and cannot be narrowed or saved by severance and therefore must be invalidated as violating the First Amendment. View "State v. Jorgenson" on Justia Law

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The Supreme Court affirmed Defendant's convictions for of first-degree premeditated murder and attempted first-degree premeditated murder but reversed Defendant's 360-month sentence for attempted first-degree premeditated murder, holding that the sentence was error because it exceeded the statutory maximum.Specifically, the Supreme Court held (1) the district court did not abuse its discretion by denying Defendant's pretrial motion to suppress his post-Miranda statements; (2) the jury instruction on the elements of premeditated murder was not erroneous, and the district court did not err by failing to give a jury instruction on accomplice testimony; and (3) because the statutory maximum for the offense of attempted first-degree premeditated murder is 240 months, Defendant's sentence on this offense is remanded for resentencing. View "State v. Ezeka" on Justia Law

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The Supreme Court affirmed the judgment of the district court determining that Appellant's claim of ineffective assistance of counsel failed under the second prong of Strickland v. Washington, 466 U.S. 668 (1984), holding that, even if Appellant had offered to plead guilty to second-degree murder, Appellant made no showing that there was a reasonable probability that the State would have entered into a plea agreement.A jury found Appellant guilty of first-degree murder while committing child abuse, second-degree felony murder, and second-degree manslaughter. Appellant later filed a postconviction motion, alleging that her counsel provided ineffective assistance by failing to recommend that she plead guilty to second-degree murder and by failing adequately to inform her about the power of the State's case. The district court concluded that Appellant had satisfied the first but not the second prong of Strickland. The Supreme Court affirmed, holding that, even assuming that defense counsel's recommendation could have persuaded Appellant to make a qualifying offer, Appellant failed to show that any such offer would have been accepted by the State and presented to the court. View "Peltier v. State" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the district court granting Defendant's motion to suppress evidence seized from his vehicle during a traffic stop, holding that a driver violates Minn. Stat. 169.30(b) by driving past the stop sign or stop line before coming to a complete stop.Defendant's vehicle was stopped after he failed to stop at a stop sign and stop line. The district court suppressed the evidence seized from Defendant's vehicle, concluding that the traffic stop was unlawful because Minn. Stat. 169.30(b) requires a driver "to stop at the intersection, not at the stop sign or stop line." The court of appeals reversed. The Supreme Court affirmed, holding (1) section 169.30(b) is violated when the driver a vehicle drives past the stop sign or stop line before coming to a complete stop; and (2) because Defendant failed to bring his vehicle to a complete stop before he drove his vehicle past the stop line and the stop sign, the traffic stop was lawful. View "State v. Gibson" on Justia Law