Justia Minnesota Supreme Court Opinion Summaries

After a jury trial, Appellant was found guilty of first-degree premeditated murder and first-degree felony murder. The district court sentenced Appellant to life imprisonment without the possibility of release on the first-degree premeditated murder conviction. The Supreme Court affirmed, holding (1) the district court did not err in denying Appellant’s motion to suppress statements he made to police; (2) the district court did not abuse its discretion when it declined to give Appellant’s requested jury instruction on circumstantial evidence; and (3) the evidence was sufficient to support Appellant’s murder convictions. View "State v. Fox" on Justia Law

After a jury trial, Appellant was found guilty of failing to register as a predatory offender. The district court imposed a presumptive sentence of sixteen months imprisonment and a ten-year conditional-release term under Minn. Stat. 422.052(3). The court imposed the conditional-release term based on a previous finding by an administrative committee of the Department of Corrections that had assessed Appellant as a high-risk, level-III offender. Several years later, Appellant moved to correct his sentence, arguing that a jury, not the judge, was constitutionally required to make the finding regarding his risk-level status. The district court denied Appellant’s motion. The court of appeals affirmed. The Supreme Court reversed and vacated Appellant’s ten-year conditional-release term, holding that Appellant had the right to have a jury determine whether he was a risk-level-III offender at the time of his offense. View "State v. Her" on Justia Law

After a jury trial, Defendant was convicted of first-degree premeditated murder and sentenced to life imprisonment without the possibility of release. The conviction arose from a homicide that occurred during an aggravated robbery. The Supreme Court affirmed, holding (1) the evidence was sufficient to uphold Defendant’s conviction, as the State introduced sufficient evidence to prove Defendant’s guilt as an accomplice to the murder; and (2) any error in the district court’s admission into evidence of recordings of portions of Defendant’s interrogation that occurred after Defendant told the officers, “ain’t no sense in talking no more man” was harmless beyond a reasonable doubt because the verdict was surely unattributable to the error. View "State v. McAllister" on Justia Law

After a jury trial, Appellant was convicted of first-degree premeditated murder and first-degree murder while committing burglary arising from the stabbing death of an eleven-year-old. The Supreme Court affirmed Appellant’s conviction for premeditated first-degree murder but vacated his conviction for first-degree murder while committing burglary. Appellant later filed a petition for postconviction relief arguing that he was entitled to a new trial to consider evidence that was purportedly new and exculpatory. The postconviction court denied the petition without holding an evidentiary hearing. Appellant subsequently brought the instant pro se petition for postconviction relief, alleging ineffective assistance of trial counsel and appellate counsel and loss of evidence claims. The postconviction court summarily denied the petition, concluding (1) appellate counsel’s representation did not fall below an objective standard of reasonableness, and (2) Appellant’s remaining claims were procedurally barred under State v. Knaffla. The Supreme Court affirmed, holding (1) Appellant’s ineffective assistance of appellate counsel claim failed as a matter of law; and (2) Appellant’s remaining claims were time barred. View "Fort v. State" on Justia Law

Appellant was convicted of first-degree premeditated murder and sentenced to life imprisonment without the possibility of release. The Supreme Court affirmed on appeal. Appellant later filed a pro se petition for postconviction relief, raising a sentencing claim, a restitution claim, and several claims of ineffective assistance of counsel and newly discovered evidence. The postconviction court granted relief on Appellant’s sentencing claim but denied relief on his other claims. Appellant appealed, arguing that the postconviction court erred when it denied his claims without an evidentiary hearing. The Supreme Court affirmed, holding that the postconviction court did not err when it summarily denied Appellant’s petition. View "Nissalke v. State" on Justia Law

Law enforcement officers searched Defendant’s home pursuant to a search warrant and found plastic bags containing methamphetamine. The search warrant was based on information police received from a warrantless search of Defendant’s garbage. Defendant was charged with third-degree possession of a controlled substance. Defendant moved to suppress the evidence, arguing that the warrantless search of his garbage violated Minn. Const. art. I, 10. The district court denied the motion to suppress. The court of appeals affirmed. At issue before the Supreme Court was whether Article I, Section 10 of the Minnesota Constitution requires greater protection than the Fourth Amendment to the United States Constitution in the context of a warrantless search of garbage set out for collection in an area accessible to the public. The Supreme Court affirmed, holding (1) there is not a principled basis for interpreting Article I, Section 10 to require greater protection that the Fourth Amendment; (2) it was lawful for the police to obtain Defendant’s garbage from the garbage collector; and (3) because the warrantless search of Defendant’s garbage was reasonable under the state and federal constitutions, the search warrant for Defendant’s residence based on evidence found in the garbage was valid. View "State v. McMurray" on Justia Law

Appellant was convicted of a crime and was sentenced to a stayed sentence of ninety-eight months together with a conditional-release term of five years. Appellant violated his probation, served a portion of his executed sentence, and was then placed on supervised release. After Appellant violated the terms of his supervised release, the Minnesota Department of Corrections (DOC) revoked his release and ordered him to serve the remaining portion of his executed sentence in custody. Appellant filed a motion to correct his sentence under Minn. R. Crim. P. 27.03(9), alleging that the DOC had illegally extended his conditional-release term. The district court concluded that it had jurisdiction over the matter and denied Appellant’s motion to correct his sentence on the merits. The Supreme Court affirmed as modified, holding (1) the district court has subject matter jurisdiction over a motion to correct a sentence under Rule 27.03(9), but such a motion is not the proper procedure to obtain judicial review of the Commissioner of Correction’s administrative decision implementing the sentence imposed by the district court; and (2) because Appellant used the wrong procedure, a denial of his motion to correct his sentence was warranted. View "State v. Schnagl" on Justia Law

Minn. Stat. 169A.20(2) (“the test refusal statute”) makes it a crime for a driver to refuse to request to take a chemical test to detect the presence of alcohol if certain conditions are met. One of those conditions is that the driver has been validly arrested for driving while impaired. Appellant argued that the test refusal statute violated due process because it criminalizes refusal to consent to an unreasonable, warrantless search of a driver’s breath. The district court dismissed the charges, concluding that the police lacked a lawful basis to search Appellant without a warrant, and therefore, the test refusal statute was unconstitutional as applied. The court of appeals reversed. The Supreme Court affirmed, holding (1) because the breath test the police asked Defendant to take would have been constitutional under the search-incident-to-arrest exception to the Fourth Amendment’s warrant requirement, charging Defendant with criminal test refusal did not implicate a fundamental right; and (2) the test refusal statute is a reasonable means to a permissive object and passes rational basis review. View "State v. Bernard" on Justia Law

After a jury trial, Appellant was convicted of premeditated first-degree murder and attempted first-degree murder. In a postconviction motion, Appellant argued that he was entitled to a new trial based on newly discovered evidence and the recantation of two witnesses. The postconviction court denied the petition after granting multiple continuances for Appellant to attempt to secure the appearance of favorable witnesses and then holding an evidentiary hearing. The Supreme Court affirmed on the merits but remanded for resentencing, holding (1) the postconviction court did not err when it refused to compel the attendance of certain witnesses at an evidentiary hearing; (2) Appellant forfeited his argument that his trial counsel provided ineffective assistance; and (3) the sentence imposed after a remand from Appellant’s direct appeal was improper. Remanded for resentencing. View "Burrell v. State" on Justia Law

Appellant pleaded guilty and was convicted of first-degree burglary. Two years after Appellant was placed on probation, he appeared before the district court regarding alleged probation violations. Appellant personally admitted the probation violations, and the district court revoked his probation. On appeal, Appellant argued for the first time that the district court erred when it violated his constitutional right to be advised of his due process rights under Morrissey v. Brewer and when it failed to provide him the rights advisory required by Minn. R. Crim. P. 27.04. The court of appeals affirmed. The Supreme Court affirmed, holding (1) a probationer does not have a separate constitutional right “to be advised” that he or she has the procedural due process rights articulated in Morrissey; and (2) the district court’s plain error in failing to provide Appellant the rights advisory requirement by Rule 27.04 did not affect his substantial rights. View "State v. Beaulieu" on Justia Law