Justia Minnesota Supreme Court Opinion Summaries

Appellant was convicted for the first-degree premeditated murder of Devan Hawkinson. Appellant and Hawkinson were friends before Hawkinson was murdered. On appeal, Appellant argued that the district court erred by admitting evidence of his past conduct and relationship with Hawkinson, contending that the evidence violated his rights under the Confrontation Clause because it included testimonial statements that Hawkinson made to the police before his death and that it was irrelevant. The Supreme Court affirmed, holding (1) any error in admitting the evidence was harmless; and (2) none of the claims raised in Appellant’s pro se briefs entitled him to relief. View "State v. Rossberg" on Justia Law

After a jury trial in 1992, Appellant was found guilty of two counts of first-degree murder and two counts of attempted first-degree murder. Appellant was fifteen years old at the time. Under a mandatory sentencing scheme, the district court imposed life sentences with the possibility of release after thirty years for the first-degree murder convictions. After the United States Supreme Court decided Miller v. Alabama in 2012, Appellant filed a postconviction motion to correct his sentence, arguing that his sentence violated the rule announced in Miller. The postconviction court denied the motion, concluding that Appellant’s sentence was lawful because Miller was not retroactive. The Supreme Court affirmed without reaching the issue of Miller’s retroactivity, holding that Miller did not make the sentencing scheme at issue here unlawful because the mandatory sentencing scheme did not require life imprisonment without the possibility of release. View "Ouk v. State" on Justia Law

The State filed a delinquency petition charging Appellant, who was then fourteen years old, with first-degree felony murder (drive-by shooting), second-degree felony murder (drive-by shooting), and attempted first-degree felony murder (drive-by shooting). Defendant pled guilty to the murder charges, but the Supreme Court vacated the convictions. On remand, the case proceeded to trial, and a jury found Appellant guilty of all three counts. The Supreme Court affirmed, holding (1) the district court had original and exclusive jurisdiction over Appellant’s offenses; (2) sufficient evidence supported Appellant’s convictions; (3) assuming that the district court improperly instructed the jury on the elements of drive-by shooting, Appellant did not establish that the error affected his substantial rights; (4) Appellant’s mandatory life sentence with the possibility of release was not unconstitutional under the principles of Miller v. Alabama; (5) the district court did not abuse its discretion by imposing a longer sentence upon Appellant after his trial and conviction; and (6) the postconviction court did not err when it summarily denied Appellant’s petition for postconviction relief. View "State v. Vang" on Justia Law

James Bergstrom and Vanessa Rew dissolved their marriage in 2008. In 2002, 2007, and 2008, Rew obtained a series of one-year orders for protection (OFPs) against Bergstrom. In 2010, before the extended expiration date of the 2008 OFP, Rew filed an application under Minn. Stat. 518B.01(6)(a) to extend the terms of the 2008 OFP. After an evidentiary hearing, the district court extended the OFP for up to fifty years in favor of Rew and the couple’s minor children. The Supreme Court affirmed in part and reversed in part, holding (1) section 518B.01(6)(a) does not require a finding of domestic abuse before a district court may extend the duration of an OFP; (2) the extension of an OFP under section 518B.01(6)(a) does not facially violate the First Amendment to the United States Constitution or Minn. Const. art. I, 3; (3) the record was insufficient to conclude that the extended OFP was constitutional with respect to Bergstrom’s children; and (4) the extension of an OFP for up to fifty years does not implicate the prohibition against double jeopardy or the Ex Post Facto Clause of either the United States of Minnesota Constitutions. Remanded. View "In re Rew" on Justia Law

In 2001, Respondent was found guilty of first-degree murder while committing or attempting to commit criminal sexual conduct and first-degree premeditated murder. Respondent was a juvenile when he committed the crime. The district court sentenced Respondent to life without the possibility of release (LWOR) under the mandatory sentencing scheme in Minn. Stat. 609.106(2)(1). After the U.S. Supreme Court decided Miller v. Alabama in 2012, Respondent filed a petition for postconviction relief, arguing that his sentence violated the Eighth Amendment. The postconviction court granted Respondent’s petition and resentenced him to life in prison with the possibility of release after thirty years. The Minnesota Supreme Court subsequently issued its decision in Chambers v. State, which held that the Miller rule does not apply retroactively to a juvenile whose sentence of LWOR under section 609.106(2)(1) became final before the Miller rule was announced. Thereafter, in the instant case, the Supreme Court reversed the postconviction court’s order and reinstated the original sentence of LWOR, holding that the postconviction court’s legal conclusion was in direct conflict with Chambers, and the circumstances of this case did not warrant granting relief to Respondent under the Court’s supervisory powers to ensure the fair administration of justice. View "Roman Nose v. State" on Justia Law

Appellant entered into a mortgage with Aegis Lending Corporation. The mortgage was later assigned to Pacifica L. Ninteen, and the servicing rights were eventually transferred to Vantium Capital, Inc. (“Acqura”). After foreclosure proceedings were commenced against Appellant, Appellant filed suit against Acqura, alleging numerous state law claims. Specifically, Appellant claimed that Acqura’s violated its Servicer Participation Agreement with Fannie Mae by failing to follow guidelines applicable under the federal Home Affordable Modification Program. The district court dismissed the lawsuit, holding that Minn. Stat. 58.18(1) did not provide a private cause of action for Appellant to pursue damages for Acqura’s alleged violation of its agreement with Fannie Mae and that Appellant therefore lacked standing. The court of appeals affirmed. The Supreme Court reversed, holding that section 58.18(1) provides for a private right of action and therefore gave Appellant standing to pursue her claim. View "Gretsch v. Vantium Capital, Inc." on Justia Law

Appellant Ronald Greer sought post-conviction relief from his murder conviction. The trial court denied relief, and he appealed that denial to the Supreme Court. Finding that the trial court did not abuse its discretion in denying Greer's petitions for relief, the Supreme Court affirmed. View "Greer v. Minnesota" on Justia Law

After a jury trial, Appellant was convicted of two counts of first-degree premeditated murder, two counts of first-degree felony murder, and three counts of first-degree aggravated robbery. The Supreme Court affirmed Appellant's convictions, holding that the district court did not err by (1) overruling Defendant's Batson objection to the State's peremptory challenge of an African-American prospective juror, as Defendant failed to prove that the challenge constituted purposeful racial discrimination; and (2) admitting evidence that Defendant assaulted and threatened a witness two days before trial to prove consciousness of guilt, as the district court correctly weighed the probative value of the evidence against the danger of unfair prejudice and provided safeguards to ensure the evidence would not unduly influence the jury's verdict.View "State v. Diggins" on Justia Law

Defendant was convicted of two counts of aiding suicide in violation of Minn. Stat. 609.215(1), which makes it illegal to intentionally “advise, encourage, or assist another in taking the other’s own life.” Defendant had responded to posts on suicide websites by encouraging the victims to hang themselves, falsely claiming that he would also commit suicide. Defendant appealed, arguing that section 609.215(1) violated the First Amendment. The court of appeals affirmed, holding that the statute prohibited speech that was unprotected by the First Amendment. The Supreme Court reversed, holding (1) the State may prosecute Defendant for assisting another in committing suicide but not for encouraging or advising another to commit suicide, and thus the words “advises” and “encourages” must be severed from the statute as unconstitutional; and (2) because the district court did not make a specific finding on whether Defendant assisted the victims’ suicides, the case must be remanded. View "State v. Melchert-Dinkel" on Justia Law

Defendant, who was HIV positive, engaged in consensual anal intercourse. Defendant was subsequently charged with attempted first-degree assault by transferring a communicable disease for violating Minn. Stat. 609.2241(2). A jury found Defendant violated section 609.2241(2)(2), which applies to the "transfer of blood, sperm, organs, or tissue." The court of appeals reversed the conviction, concluding that section subdivision 2(2) applies only to medical procedures instead of applying to acts of sexual conduct. The Supreme Court affirmed, holding (1) subdivision 2(2) applies only to the donation or exchange for value of blood, sperm, organs, or tissue; and (2) because Defendant's conduct indisputably did not involve the donation or exchange for value of his sperm, subdivision 2(2) was inapplicable to Defendant's conduct.View "State v. Rick" on Justia Law