Justia Minnesota Supreme Court Opinion Summaries

Defendant was convicted of murder in the first degree while committing domestic abuse and with a past pattern of domestic abuse. Defendant subsequently filed a petition for postconviction relief, arguing, among other things, that there was insufficient evidence to establish a past pattern of domestic abuse beyond a reasonable doubt. After an evidentiary hearing, the postconviction court denied the petition. The Supreme Court affirmed, holding (1) sufficient evidence supported the jury’s finding that Defendant engaged in a past pattern of domestic abuse against the victim; (2) the district court did not err in its jury instructions on a past pattern of domestic abuse; and (3) the district court did not commit plain error by admitting evidence connected to orders for protection obtained by the victim, as Appellant’s substantial rights were not affected by the admission of this evidence. View "Gulbertson v. State" on Justia Law

Law enforcement officers stopped a truck driven by Thomas Anthony, a suspected drug dealer. Charles Lemert was a passenger in Anthony’s car. Officers ordered Lemert to get out of the truck and proceeded to conduct a pat search of Lemert. Based on the evidence discovered during the pat search, the State charged Lemert with a fifth-degree controlled-substance offense. Lemert moved to suppress the evidence, arguing that the search was unlawful because the officers lacked a reasonable, articulable suspicion that Lemert might have been armed and dangerous. The district court denied the motion and convicted Lemert of the charge. The court of appeals affirmed. The Supreme Court affirmed, holding that, under the circumstances, the officers had a reasonable, articulable suspicion that Lemert might have been armed and dangerous, and therefore, the district court did not err when it denied Lemert’s motion to suppress. View "State v. Lemert" on Justia Law

After a jury trial in 1994, Defendant was convicted of first-degree murder and sentenced to life in prison with the possibility of release. Seven months later, Defendant pleaded guilty to second-degree attempted murder. The court sentenced Defendant to an additional seventy-two months in prison to run consecutively to his life sentence. In 2012, Defendant filed a pro se motion to correct his sentence under Minn. R. Crim. P. 27.03(9). The district court treated the motion as a petition for postconviction relief and then denied the motion on the grounds it was time barred and procedurally barred. The Supreme Court affirmed, holding that even if Defendant's motion was not time barred or procedurally, barred, his argument that the overall length of his imprisonment should be reduced failed on the merits.View "Townsend v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and sentenced to life in prison. Defendant subsequently filed two petitions for postconviction relief, both of which were denied. The instant appeal concerned the postconviction court’s summary denial of Defendant’s second petition for postconviction relief. On appeal, Defendant raised three claims: ineffective assistance of appellate counsel, prosecutorial misconduct, and ineffective assistance of trial counsel. The Supreme Court affirmed, holding that the postconviction court did not err by summarily denying Defendant’s second petition for postconviction relief because all three of Defendant’s claims failed as a matter of law. View "Erickson v. State" on Justia Law

Law enforcement officers obtained a warrant to search Appellant and Appellant’s residence after Appellant allegedly threatened a woman for stealing his drugs. At the apartment the officers seized gun and drug evidence. Appellant filed a motion to suppress, which the district court granted on the ground that the search warrant affidavit failed to establish a sufficient nexus between Defendant’s alleged criminal activity and the apartment. The court of appeals reversed. The Supreme Court affirmed, holding that, based on the totality of the circumstances, the search warrant affidavit established a sufficient nexus between Appellant’s alleged criminal activity and the place to be searched. View "State v. Yarbrough" on Justia Law

After a jury trial, Appellant was convicted of first-degree felony murder while committing a drive-by shooting for the benefit of a gang. The Supreme Court stayed Appellant’s direct appeal to permit Appellant to file a petition for postconviction relief. The postconviction court subsequently denied relief. The Supreme Court consolidated Appellant’s direct and postconviction appeals into a single proceeding and held (1) the record contained sufficient evidence to support Appellant’s conviction; (2) some of the individual jury instructions in this case were erroneous, but the jury instructions, considered as a whole, did not constitute reversible error; (3) Appellant knowingly and voluntarily waived his right to testify at trial; (4) Appellant was not deprived of his right to the effective assistance of trial counsel; (5) the district court did not abuse its discretion when it denied Appellant’s motion for a mistrial; (6) the jury did not return legally inconsistent verdicts; and (7) the postconviction court did not err when it denied an evidentiary hearing on Appellant’s claim that the district court violated his right to a public trial. View "State v. Bahtuoh" on Justia Law

Defendant was convicted of first-degree murder and sentenced to life imprisonment. The Supreme Court affirmed the conviction on direct appeal. Defendant subsequently filed several petitions for postconviction relief. Defendant's fourth petition for postconviction relief alleged that new evidence, an unsworn statement by an alleged eyewitness to the murder, entitled him to a new trial. After an evidentiary hearing, the postconviction court denied Defendant's fourth petition for postconviction relief. The Supreme Court affirmed, holding that the postconviction court (1) did not err in denying Defendant a new trial based on new evidence; (2) did not abuse its discretion in how it handled evidence that Defendant submitted after the evidentiary hearing; and (3) did not err in refusing to grant relief in the interests of justice. View "Miles v. State" on Justia Law

After a jury trial, Defendant was convicted of two counts of felony violation of a domestic abuse no-contact order. The court of appeals reversed and remanded for a new trial, holding (1) the failure to instruct on an element of the charged offense as a matter of law affects a defendant's substantial rights, and (2) Defendant's substantial rights were affected as a matter of law by the district court's failure to instruct the jury on the "knowingly" element of the charged offense. The Supreme Court affirmed but on different grounds, holding (1) an unobjected-to jury instruction that omits an element of the charged offense does not, as a matter of law, affect a defendant's substantial rights, but rather, the trial court must consider certain factors to determine whether the omission of an element of a charged offense from the instruction to the jury was sufficiently prejudicial to warrant a new trial; and (2) the trial court's failure to instruct on the "knowingly" element of the charged offense was an error that affected Defendant's substantial rights. View "State v. Watkins" on Justia Law

Defendant was charged with first-degree premeditated murder for the benefit of a gang. Defendant was acquitted of the first-degree murder offense but convicted of the lesser-included offense of second-degree intentional murder for the benefit of a gang. The Supreme Court vacated the second-degree murder conviction on appeal. On remand, a second grand jury indicted Defendant with first-degree felony murder for the benefit of a gang and second-degree intentional murder for the benefit of a gang. After Defendant unsuccessfully filed a motion to dismiss the felony murder charge on the grounds that the charge violated constitutional and statutory prohibitions against double jeopardy, Defendant was found guilty of the first-degree felony murder and second-degree intentional murder charges. The trial court convicted Defendant on the second-degree murder offense. The Supreme Court (1) affirmed the conviction of second-degree intentional murder for the benefit of a gang, holding that the State presented sufficient evidence to support the conviction; and (2) reversed the district court's denial of Defendant's pretrial motion to dismiss, holding that the court failed properly to analyze the double jeopardy issue. View "State v. Chavarria-Cruz" on Justia Law

After a jury trial, Respondent was convicted of third-degree criminal conduct in violation of Minn. Stat. 609.344(1)(l)(i) (the clergy-sexual-conduct statute) based on a sexual relationship between Respondent, a Roman Catholic priest, and a parishioner. The court of appeals reversed, holding (1) the clergy-sexual-conduct statute is not facially unconstitutional; but (2) the statute violated the Establishment Clause as applied to Respondent. the Supreme Court affirmed in part and reversed in part, holding (1) the clergy-sexual-conduct statute does not facially violate the Establishment Clause; and (2) Respondent did not prove that the clergy-sexual-conduct statute as applied violated the Establishment Clause. Remanded. View "State v. Wenthe" on Justia Law