Justia Minnesota Supreme Court Opinion Summaries

Articles Posted in Constitutional Law
by
The Supreme Court affirmed Defendant's conviction of first-degree premeditated murder and his sentence of life in prison without the possibility of release, holding that Defendant was not entitled to relief on his allegations of error.Specifically, the Supreme Court held (1) the district court did not violate Defendant's Sixth Amendment right to confrontation when it admitted the victim's dying declarations into evidence during the jury trial, and this Court reaffirms that dying declarations are an exception to the Confrontation Clause; (2) the district court did not violate Defendant's Fifth Amendment right to counsel by denying Defendant's motion to suppress his statements to police officers because Defendant validly waived his invoked right to counsel; and (3) there was no reasonable possibility that the admission of Spreigl evidence related to a prior assault charge into evidence significantly affected the verdict. View "State v. Buchan" on Justia Law

by
The Supreme Court reversed the judgment of the court of appeals denying Defendant's motion for a new trial, holding that the record was insufficient to determine whether Defendant's right to a public trial was violated due to restrictions put in place by the district court arising from the COVID-19 pandemic.In December 2019, Defendant was charged with first-degree aggravated robbery. Because of the restrictions placed on trials due to the pandemic the county submitted a trial plan that excluded all spectators from the courtroom but included a one-way video feed that would broadcast the trial in an adjacent courtroom. The trial court overruled Defendant's objection, and the trial proceeded. After Defendant was convicted he moved for a new trial. The court of appeals denied the motion. The Supreme Court reversed, holding that additional findings were required on the decision to close the courtroom before it could be determined whether Defendant's public trial right was violated. View "State v. Bell" on Justia Law

by
In this interlocutory appeal, the Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court granting Defendant's motion to suppress statements recorded on a body-worn camera, holding that the district court did not abuse its discretion in determining that the statements should be suppressed.In response to a domestic disturbance 911 call law enforcement officers found A.H. locked out of her apartment while Defendant was inside, and A.H. told the officers that Defendant had assaulted her both in the present and in the past. These statements were recorded by an officer's body-worn camera. Defendant was subsequently charged with one count of misdemeanor domestic assault. The district court granted Defendant's motion to suppress the body-worn camera recording on the grounds that their admission would violate Defendant's constitutional right to confrontation. The court of appeals affirmed. The Supreme Court affirmed, holding that the district court (1) did not abuse its discretion in determining that A.H.'s statements did not qualify as excited utterances under Minn. R. Evid. 802(2); and (2) properly suppressed the statements as inadmissible hearsay. View "State v. Tapper" on Justia Law

by
The Supreme Court affirmed the judgment of the district court concluding that an unconstitutional provision in a proposed charter amendment was not severable, holding that the provision was not severable from the remainder of the proposed charter amendment.On August 8, 2022, the Bloomington City Council voted to reject the entirety of a proposed charter amendment based on its conclusion that the last of the proposed amendment's four sections, section 4.08, was manifestly unconstitutional. Appellants filed a petition seeking declaratory and injunctive relief to sever section 4.08 and submit the remaining valid provisions to voters. The district court denied the petition, concluding that it would be improper to sever section 4.08 from the remainder of the proposed charter amendment. The Supreme Court affirmed, holding that section 4.08 could not properly be severed from the proposed city-charter amendment. View "Kranz v. City of Bloomington" on Justia Law

by
The Supreme Court affirmed the judgment of the district court denying Appellant's petition for postconviction relief from his conviction for first-degree felony murder under an aiding and abetting theory of criminal liability, holding that Appellant's arguments did not entitle him to relief.In his petition for postconviction relief, Appellant claimed in part that he received ineffective assistance of trial counsel because counsel did not communicate an Alford plea deal to him. The district court denied the petition, concluding that Appellant failed to prove his claim by a preponderance of the evidence. The Supreme Court affirmed, holding that the evidence established beyond a reasonable doubt that Appellant committed first-degree felony murder under an aiding and abetting theory of criminal liability. View "State v. King" on Justia Law

by
The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of fifth-degree possession of a controlled substance, holding that the search of Defendant's purse was constitutional under the automobile exception to the Fourth Amendment's search warrant requirement.Defendant, a passenger in a vehicle searched by law enforcement without a warrant, removed her purse from the car as she got out, but an officer directed her to leave the purse on the car. The officer's ensuing search of the purse revealed a controlled substance. Defendant filed a motion to suppress, arguing that the automobile exception did not apply because the purse was an extension of her person, not a container within the car. The district court denied the motion. The court of appeals affirmed the denial, concluding that the warrantless search of Defendant's purse was constitutional. The Supreme Court affirmed, holding that (1) the purse was a container that was inside the car at the time probable cause arose; and (2) because the purse could have contained marijuana, the officer was permitted to search it under the automobile exception. View "State v. Barrow" on Justia Law

by
The Supreme Court reversed the opinion of the court of appeals reversing Defendant's convictions for driving after cancellation-inimical to public safety (DAC-IPS) based on the conclusion that Minn. Stat. 171.24, subd. 5 is unenforceable on private property, holding that the statute is enforceable on private property.Defendant, whose license was cancelled as inimical to public safety, was charged with DAC-IPS after a law enforcement officer observed him drive a motor vehicle down a private driveway. Defendant filed a motion to suppress and to dismiss the complaint for lack of probable cause. The district court denied the motions. The district court subsequently found Defendant guilty. The court of appeals reversed, ruling that the DAC-IPS requires a license only when a vehicle is operated on a street or highway. The Supreme Court reversed, holding (1) the DAC-IPS statute is enforceable in private property; and (2) the district court properly denied Defendant's motions to suppress and dismiss, resulting in restatement of Defendant's convictions. View "State v. Velisek" on Justia Law

by
The Supreme Court affirmed the judgment of the court of appeals granting the petition for a writ of prohibition filed by the State prohibiting the district court from enforcing a "taint team" order, holding that the district court erred in concluding that the Sixth Amendment right to counsel was implicated in this case.Appellant, a juvenile at the time of his offense, was convicted of first-degree premeditated murder and sentenced to two consecutive sentences of life without the possibility of release. After Miller v. Alabama, 467 U.S. 460 (2012), was decided, Appellant was granted resentencing. At issue during the hearing was copies of recorded calls made by Appellant while he was incarcerated. The district court ordered the State to use a taint team to review the recorded calls for attorney-client communications on the ground that Appellant's the constitutional right to counsel was implicated. The court of appeals granted the State's petition for a writ prohibiting the court from enforcing the taint team order. The Supreme Court affirmed, holding that relief was not warranted because (1) the Sixth Amendment was not implicated here; and (2) the State would be injured and without any adequate remedy to correct the unauthorized action of the court. View "State v. Flowers" on Justia Law

by
The Supreme Court affirmed the judgment of the district court dismissing this lawsuit brought by Appellants seeking a declaration "that individuals are restored to civil rights and possess the fundamental right to vote guaranteed by [Minn. Const. art. VII] by virtue of being released or excused from incarceration following a felony," holding that there was no error.At issue before the Supreme Court was (1) whether Minn. Const. art. VII, 1 requires that a person convicted of a felony be restored to the right to vote upon being released or excused from incarceration; and (2) whether Minn. Stat. 609.165 is contrary to the fundamental right to vote or to equal protection protections under the state Constitution. The Supreme Court held (1) under article VII, section 1, a person convicted of a felony cannot vote in Minnesota unless his or her right to vote is restored in accordance with an affirmative act or governmental mechanism restoring the person's right to vote; and (2) section 609.165 does not violate the fundamental right to vote, and there was insufficient evidence to prove that the statute violates the Minnesota Constitution's equal protection principle. View "Schroeder v. Simon" on Justia Law

by
The Supreme Court affirmed the opinion of the court of appeals affirming the decision of the district court to allow a witness to testify using live, two-way remote view technology during a jury trial in the midst of the COVID-19 pandemic, holding that Defendant's right to confrontation was not violated in the proceedings below.During Defendant's jury trial on a third-degree sale of a controlled substance charge, the district court allowed one of the State's witness to testify via Zoom because she had been exposed to COVID-19 and was forced to quarantine. Defendant appealed. The Supreme Court affirmed, holding (1) the two-part test set forth in Maryland v. Craig, 497 U.S. 836 (1990), is the appropriate test to assess whether a Confrontation Clause violation under the federal or state constitutions; and (2) Defendant's right to confrontation under the federal and state constitutions when the district court permitted the witness to testify using remote view technology under the circumstances of this case. View "State v. Tate" on Justia Law