Justia Minnesota Supreme Court Opinion Summaries

Appellant was charged with first- and third-degree on the ground that Appellant injured a young child in his care. A jury found Appellant not guilty of both charges, and the district court entered a judgment of acquittal. Appellant then petitioned the district court for an order sealing the criminal records related to the alleged assault. The district court granted Appellant's petition, concluding that the State failed to prove by clear and convincing evidence that the public's interests outweighed Appellant's interests pursuant to Minnesota's expungement statute. The court of appeals reversed, finding that Appellant proved no specific disadvantage to himself against which to balance the interests of the public. The Supreme Court reversed the decision of the court of appeals, holding that an expungement petitioner is not required to prove specific disadvantages he or she will suffer if the petition is denied and may instead satisfy his or her burden of production simply by establishing the fact of his or her acquittal. View "State v. R.H.B." on Justia Law

Appellant pled guilty to first-degree murder while committing domestic abuse and was sentenced to life imprisonment with the possibility of parole. Defendant did not appeal but subsequently filed a postconviction petition, alleging that his guilty plea was invalid because it lacked a proper factual foundation. The postconviction court denied relief on the ground that the petition was untimely and lacked substantive merit. The Supreme Court affirmed, holding (1) because there was sufficient evidence of a past pattern of domestic abuse and sufficient evidence of an extreme indifference to human life, Appellant's claim that he was entitled to withdraw his plea failed on the merits, and therefore, Appellant failed to establish a manifest injustice entitling him to withdraw his guilty plea; and (2) therefore, the Court did not need to reach the remaining issues raised in this appeal. View "Lussier v. State" on Justia Law

Appellant was found guilty by a jury of first-degree murder while committing malicious punishment of a child with a past pattern of child abuse for the death of his seventeen-month-old stepson. The supreme Court affirmed Appellant's conviction, holding (1) the district court did not abuse its discretion or violate Appellant's right to present an alternative perpetrator defense in limiting access to social services records; (2) the district court did not err in ruling that potential reverse-Spreigl evidence was inadmissible or violate Defendant's right to present an alternative perpetrator defense in doing so; (3) the State presented sufficient evidence to prove the element of a past pattern of child abuse beyond a reasonable doubt; (4) the jury instructions on the element of a past pattern of child abuse fairly and correctly stated the applicable law; and (5) Defendant's defense counsel did not engage in ineffective assistance of counsel by failing to object to the jury instructions, as the jury instructions given were not erroneous. View "State v. Hokanson" on Justia Law

Following a jury trial, Appellant was convicted of first-degree felony murder, attempted second-degree criminal sexual conduct, and second-degree assault. The Supreme Court affirmed the convictions. Fourteen years later, Appellant filed his second petition for postconviction relief, which the postconviction court summarily denied as untimely filed. Appellant appealed, contending that his petition should be considered because it was not frivolous and was in the interests of justice pursuant to Minn. Stat. 590.01, 4(b) The Supreme Court affirmed, holding that Appellant's postconviction claims were time-barred under section 590.01, 4, and that Appellant's petition failed to satisfy the interests-of-justice exception in Minn. Stat. 590.01, 4(b)(5) because each of the claims in the petition was frivolous. View "Wallace v. State" on Justia Law

After a jury trial, Defendant was convicted of one count of first-degree felony murder and one count of attempted first-degree felony murder. The Supreme Court affirmed Defendant's convictions, holding (1) the district court did not err by refusing to suppress shell casings seized from the back stairway of Defendant's multifamily residence, as their seizure satisfied the plain-view exception to the presumptive rule against warrantless seizures; (2) the State did not commit prosecutorial misconduct when it referenced shell casings found in Defendant's truck; (3) the district court plainly erred when it failed to instruct the jury that, in order to find Defendant guilty of attempted first-degree felony murder, the jury had to find Defendant intentionally aided his alleged accomplices in the commission of the crime, but this error did not warrant the grant of a new trial. View "State v. Milton" on Justia Law

After a jury trial, Defendant was convicted of first-degree felony murder, second-degree intentional murder, and being a prohibited person in possession of a firearm for the shooting death of a cab driver. The district court sentenced Defendant to life imprisonment on the first-degree felony murder conviction and to a sixty-month concurrent sentence on the firearm conviction but did not sentence Defendant on the second-degree intentional murder conviction. The Supreme Court vacated Defendant's second-degree intentional murder conviction but otherwise affirmed Defendant's convictions, holding (1) the district court did not err when it declined Defendant's request for a jury instruction on accomplice testimony; (2) the district court did not abuse its discretion when it instructed the jury to continue deliberating after the jury indicated it was deadlocked; and (3) the district court erred by convicting Defendant of both first- and second-degree murder because second-degree intentional murder is a lesser-included offense of first-degree murder. View "State v. Cox " on Justia Law

Appellant was convicted of aiding and abetting first-degree felony murder. The district court sentenced Appellant to life in prison. On appeal, Appellant claimed that numerous errors entitled him to a new trial. The Supreme Court affirmed Appellant's conviction, holding (1) the jury's verdict was unattributable to any error in admitting Appellant's statement recorded after he allegedly invoked his right to remain silent, and therefore, the admission of the statement into evidence was harmless; (2) the district court did not plainly err by allowing fear testimony at trial; (3) the district court did not abuse its discretion by not admitting certain hearsay statements; (4) the district court did not plainly err by giving a no-adverse-inerence jury instruction without Appellant's clear consent; and (5) Appellant was not entitled to a new trial based on the cumulative effect of the district court's errors. View "State v. Davis" on Justia Law

Appellant was arrested and charged with first-degree premeditated murder. At trial, Appellant admitted shooting the victim, but claimed he did so in self-defense and without premeditation. The jury, rejecting Appellant's self-defense claim, found Appellant guilty of first-degree premeditated murder, and the district court sentenced Appellant to life in prison without the possibility of release. Appellant thereafter filed a petition for postconviction relief, which the postconviction court denied. The Supreme Court affirmed Appellant's conviction and the postconviction court's denial of postconviction relief, holding that each of Appellant's claims was either without merit or did not result in prejudice to Appellant. View "State v. Radke" on Justia Law

In these two cases, Petitioners, members of the Minnesota Legislature and others, filed petitions pursuant to Minn. Stat. 204B.44 seeking an order requiring Mark Ritchie, the Minnesota Secretary of State, to use the titles designated by the Minnesota Legislature for two proposed constitutional amendment ballot questions that were scheduled to appear on the November 2012 general election ballot. Petitioners contended that by failing to use the title designated by the Legislature for each ballot question, Respondents failed to comply with the statutory requirement to "provide an appropriate title" for the ballot question. The Supreme Court granted the petitions, holding that when the Legislature has included a title for a ballot question in the bill proposing a constitutional amendment, the "appropriate title" the Secretary of State must provide for that ballot question is the title designated by the Legislature. View "Limmer v. Ritchie" on Justia Law

Appellant was convicted of first-degree murder while committing a drive-by shooting and drive-by shooting. The Supreme Court affirmed Defendant's conviction. In this case, Defendant appealed the summary denial of his second petition for postconviction relief, which alleged a claim of ineffective assistance of appellate counsel, and his third petition for postconviction relief, which alleged a claim of newly discovered evidence. The Supreme Court (1) affirmed the postconviction court's summary denial of the second postconviction petition because the record conclusively showed appellate counsel was not ineffective; but (2) reversed the court's summary denial of the third postconviction petition and remanded for an evidentiary hearing because the record failed to conclusively show that Appellant was not entitled to relief based on his claim of newly discovered evidence. View "Bobo v. State" on Justia Law