Justia Minnesota Supreme Court Opinion Summaries

Articles Posted in Constitutional Law
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The Supreme Court affirmed the judgment of the district court imposing a mandatory five-year conditional release term in connection with Defendant's conviction of fourth-degree assault of a secure treatment facility employee of the Minnesota Sex Offender Treatment Program (MSOP), holding that there was a rational basis for the sentencing disparity at issue in this case.After he was convicted, Defendant filed a petition for postconviction relief arguing that Minn. Stat. 609.2231, subd. 3a(e) required the district court to impose different sentences for the same conduct based on the defendant's civil commitment status, and therefore, his sentence violated his equal protection rights under the United States and Minnesota Constitutions. The district court denied postconviction relief, and the court of appeals affirmed. The Supreme Court affirmed, holding that the disparate sentence survived rational basis review. View "State v. Lee" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals affirming Defendant's convictions on two counts of first-degree burglary and two counts of second-degree assault, holding that there was no error.After the jury announced its verdicts in this case Defendant exercised his right to poll the jury. While the record showed that the jury was composed of twelve members, the transcript of the jury polling contained only eleven responses. On appeal, Defendant argued that the evidence was insufficient to prove that he was afforded his constitutional right to a unanimous, twelve-person jury. The court of appeals affirmed. The Supreme Court affirmed, holding (1) sufficient evidentiary support in the record established that Defendant was found guilty by a twelve-member jury; and (2) Defendant was not entitled to relief for any error in the jury polling because it was not a structural error, and Defendant did not satisfy the plain error doctrine. View "State v. Bey" on Justia Law

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The Supreme Court affirmed the judgment of the court of appeals affirming the judgment of the district court finding Defendant guilty of four counts of violence under Minn. Stat. 609.713, subd. 1, holding that section 609.713, subd. 1 does not violate the First Amendment.After he was charged, Defendant filed a motion to dismiss, claiming that the portion of section 609.713, subd. 1 that applies to threats of violence made "in a reckless disregard of the risk of causing such terror" was unconstitutionally overbroad. The district court denied the motion and found Defendant guilty. The court of appeals affirmed, concluding that even if the statute prohibited some protected speech, it was not facially overbroad under the First Amendment. The Supreme Court affirmed, holding (1) specific intent is not required to make a communication a true threat; (2) the statute punishes only reckless speech that is a true threat; and (3) because few situations of reckless but protected threats would be swept up in criminal prosecutions, the statute is not facially overbroad. View "State v. Mrozinski" on Justia Law

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The Supreme Court held that certain congressional districts were unconstitutional for purposes of the 2022 primary and general elections, enjoined their use in these elections, and adopted the congressional district boundaries as set forth in Appendices A and B to this order.Two sets of plaintiffs initiated actions in, respectively, Carver County District Court and Ramsey District Court alleging that the current congressional and legislative election districts were unconstitutionally malapportioned in light of the 2020 census. The Chief Justice appointed a panel to hear and decided the consolidated action and any other challenges to the congressional and legislative districts. The Supreme Court held that the existing congressional districts were unconstitutional and adopted the congressional district boundaries as set out in Appendices A and B to this order. View "Wattson v. Simon" on Justia Law

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The Supreme Court affirmed in part and reversed in part the decision of the district court declaring that the unanimity requirement in Minn. Stat. 638.02, subd. 1 violates Minn. Const. art. V, 7, holding that the statutory provisions at issue are not unconstitutional.Defendant was convicted of first-degree manslaughter and later filed an application for a pardon absolute. The application was denied because the Board of Pardons members did not unanimously agree that Defendant was entitled to a pardon. Defendant then filed this action for declaratory and injunctive relief. The district court concluded that the unanimity requirement violates Article V, Section 7 but does not violate Article III, Section 1 of the Minnesota Constitution. The Supreme Court reversed in part, holding that the unanimity requirement does not violate either Article V, Section 7 or Article III, Section 1. View "Shefa v. Ellison" on Justia Law

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The Supreme Court affirmed the decision of the district court summarily denying as time-barred Defendant's second petition for postconviction relief, holding that even if the facts alleged in the petition were proven at an evidentiary hearing, Defendant still would not be entitled to relief.Defendant was convicted of first-degree premeditated murder. The Supreme Court affirmed both Defendant's conviction on direct appeal and the denial of his first postconviction motion. In his second postconviction petition, Defendant argued the the district court lacked subject matter jurisdiction, that he had discovered new evidence, prosecutorial misconduct, and ineffective assistance of counsel. The district court denied the petition. The Supreme Court affirmed, holding that Defendant's claims either failed on the merits or were time barred. View "Martin v. State" on Justia Law

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The Supreme Court held that the unanimity requirement in Minn. Stat. 638.02m, subd. 1 does violate either Minn. Const. art. V, 7 or Minn. Const. art. III, 1.Defendant was convicted of first-degree manslaughter. When Defendant later filed an application for a pardon absolute, the members of the Board of Pardons denied it. Attorney General Keith Ellison and Governor Tim Walz voted to grant the application, and Chief Justice Lorie Gildea voted to deny it. Defendant's application was ultimately denied. Defendant then filed an action for declaratory and injunctive relief. The district court held (1) the unanimity requirement violates article V, section 7, which gives the governor sufficient and separate power to grant pardons; and (2) the unanimity requirement violates article III, section 1 because the state Constitution explicitly provides for the chief justice's participation in the pardon process. The Supreme Court reversed in part and affirmed in part, holding that the statutory provisions did not violate article V, section 7 or article III, section 1 of the Minnesota Constitution. View "Shefa v. Ellison" on Justia Law

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The Supreme Court reversed Defendant's conviction of illegal possession of ammunition, holding that the district court erred by denying Defendant's motion to suppress.During a traffic stop, law enforcement officers questioned Defendant, who was a passenger in the stopped vehicle, regarding the conditions of his pretrial release. After Defendant was arrested for violating a condition of his pretrial release, a pat-down search revealed ammunition in Defendant's pocket. Defendant filed a motion to suppress, arguing that the officer’s questions about the conditions of his pretrial release improperly expanded the scope of the traffic stop. The district court denied the motion, and the court of appeals affirmed. The Supreme Court reversed, holding (1) violation of a condition of pretrial release does not constitute criminal activity allowing a law enforcement officer to expand the scope of a traffic stop; and (2) the officer's questioning of Defendant about the conditions of his pretrial release exceeded the permissible scope of a traffic stop. View "State v. Sargent" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals holding that a law enforcement officer lawfully expanded the scope of the underlying traffic stop in this case, holding the court of appeals did not err.Defendant was convicted of first-degree driving while impaired and possessing an opened bottle or receptacle containing an alcoholic beverage. On appeal, Defendant argued that the district court erred by denying his motion to suppress evidence because the officer impermissibly expanded the scope of the underlying traffic stop by asking Defendant if he had consumed any beer from the open case in his vehicle. The court of appeals affirmed. The Supreme Court affirmed, holding that the circumstances known to the officer and the legitimate inferences to be drawn from them raised a reasonable articulable suspicion of other criminal activity sufficient to expand the scope of the traffic stop. View "State v. Taylor" on Justia Law

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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