Justia Minnesota Supreme Court Opinion Summaries

Elizabeth Hawes was convicted of aiding and abetting her brother, Andrew Hawes, in the first-degree murder of their brother, Edwin Hawes. The district court sentenced Hawes to life imprisonment. The Supreme Court affirmed Hawes' conviction, holding (1) the circumstantial evidence was legally sufficient to support Hawes' conviction of aiding and abetting first-degree premeditated murder; (2) any error the the district court made when it ruled that out-of-court statements made by Andrew were not admissible as declarations against penal interest was harmless beyond a reasonable doubt; and (3) the district court did not abuse its discretion when it denied Hawes' motion for a new trial on the grounds of newly available evidence. View "State v. Hawes" on Justia Law

Toby Johnson was indicted for intentional murder while committing a kidnapping, murder in the second degree, and kidnapping. Pursuant to a plea agreement, the State amended the first count to aiding and abetting first-degree murder. Johnson then pleaded guilty to counts one and two. Johnson was sentenced to life in prison with a possibility of parole after thirty years. The postconviction court denied Johnson's petition for postconviction relief, and the Supreme Court affirmed. Later, Johnson filed a motion to correct or reduce his sentence, alleging that his guilty plea was invalid for several reasons. The district court concluded that the sentencing court had erred during the sentencing hearing by citing to the second-degree murder statute when imposing a sentence for first-degree murder. As to Johnson's other reasons for requested relief, the court concluded that the Supreme Court's rule from State v. Knaffla barred Johnson from raising claims that were not raised in his first petition for postconviction relief. On appeal, the Supreme Court affirmed the postconviction court's denial of Johnson's motion challenging the validity of his guilty plea, holding that Johnson's petition was untimely and should not be considered on the merits. View "Johnson v. State" on Justia Law

This case involved the assault of a pregnant woman, who, after the assault, received a cesarean section. The baby, named Destiny, later died. After a jury trial, Dameon Gatson was convicted of first-degree premeditated murder for aiding the perpetrator in the killing of Destiny and first-degree assault. On appeal, the Supreme Court affirmed, holding (1) the trial court did not err when it upheld the State's strike of a prospective juror; (2) the evidence was sufficient to support the verdict; (3) the trial court did not err by not instructing the jury on whether Destiny was a "human being" for purposes of the homicide statutes and on whether the removal of Destiny's life support was a superseding intervening cause of her death; (4) any error in admitting portions of the perpetrator's guilty plea was harmless beyond a reasonable doubt and any violation of Gatson's right to confrontation was harmless; (5) Gatson was not entitled to relief on his claim that the admission of the perpetrator's guilty plea violated hearsay rules; and (6) the trial court did not abuse its discretion in denying Gatson's motion for a new trial based on newly discovered evidence. View "State v. Gatson" on Justia Law

John Miles was convicted of first-degree murder. Miles filed a petition for postconviction relief, alleging that he was entitled to a new trial on the basis of newly discovered evidence, specifically, the information in an interview between Miles's counsel and a witness of the homicide, who stated that Miles was not responsible for the shooting of the victim. The postconviction court denied the petition, concluding that it was time-barred under Minn. Stat. 590.01. On review, the Supreme Court affirmed without prejudice, holding (1) the postconviction court erred when it determined that the witness's statement could have been discovered by the exercise of due diligence prior to trial, (2) the postconviction court applied the wrong legal test when it concluded that the witness's statement did not establish by a clear and convincing standard that Miles was innocent, but (3) the court did not err when it denied Miles's petition without a hearing because Miles failed to offer newly discovered evidence with sufficient indicia of reliability to warrant relief under the statute. The Court concluded if Miles could base a new petition on a more satisfactory showing of a genuine statement from the witness, he was entitled to file a new petition. View "Miles v. State" on Justia Law

Daniel Dalbec was found guilty of third-degree criminal sexual conduct. At Dalbec's trial, counsel for the State and Dalbec agreed to submit written closing arguments to the trial court, but defense counsel failed to submit a closing argument. On appeal, Delbec argued that he was entitled to a new trial based on a structural error that allegedly occurred when the trial court adjudicated his guilt without having received a closing argument from his counsel. The court of appeals reversed Dalbec's conviction and granted Dalbec a new trial based on the structural error. The Supreme Court granted the State's petition for review and reversed the court of appeals. At issue was whether defense counsel's failure to submit a written closing argument constituted structural error requiring automatic reversal and a new trial. The Court held (1) defense counsel's failure to submit a closing argument did not result in structural error, and (2) the trial court's adjudication of Dalbec's guilt without the benefit of closing argument was not structural error. Remanded. View "State v. Dalbec" on Justia Law

Appellant Andy Prtine was convicted of first-degree felony murder for the stabbing death of Brent Ward. On appeal, Appellant argued that he was denied effective assistance of counsel because his attorney conceded in his closing argument without Appellant's consent that Appellant intended to kill Ward. The Supreme Court held that Appellant's counsel conceded guilt with respect to the element of intent to kill in his statement and remanded to the district court to determine whether Appellant acquiesced in his trial counsel's concession of intent to kill. The district court ruled that Appellant acquiesced in his counsel's concession that the killing was intentional. The Supreme Court affirmed Appellant's conviction, holding that (1) Appellant acquiesced in the concession, and (2) because Appellant acquiesced in his trial counsel's concession of guilt with respect to intent to kill, Appellant was not entitled to a new trial based on his ineffective-assistance-of-counsel claim. View "State v. Prtine" on Justia Law

After a jury trial, Jack Nissalke was convicted of first-degree premeditated murder and sentenced to life imprisonment. On appeal, the Supreme Court affirmed, holding (1) Nissalke was not entitled to a new trial based on the district court's entry into the jury room and communication with the jury outside the presence of counsel and Nissalke while the jury was deliberating; (2) the district court did not violate Nissalke's right to present a complete defense by refusing to admit certain alternative perpetrator evidence; (3) the State did not commit prejudicial misconduct by asserting facts not in evidence in opening statements and closing arguments and by shifting the burden of proof to Nissalke in closing; (4) although the district court erred by failing to remove a biased juror for cause, this error did not require reversal; (5) the evidence was sufficient to support Nissalke's conviction; (6) the State did not violate Nissalke's due process rights by failing to preserve physical evidence; and (7) Nissalke was not entitled to a new trial based on his claims of ineffective assistance of counsel. View "State v. Nissalke" on Justia Law

After a jury trial, appellant Justin Buckingham was convicted of attempted first-degree premeditated murder and attempted first-degree drive-by-shooting murder. The Supreme Court affirmed appellant's convictions but modified his sentence. Appellant subsequently filed a petition for postconviction relief, asserting that the district court admitted his statements to police in violation of his constitutional rights, his court-ordered psychological evaluation was incomplete, the district court gave the jury an erroneous accomplice liability instruction, and his trial counsel was ineffective. The district court denied Buckingham's petition for relief without a hearing, rejected Buckingham's claims on the merits, and held that most of Buckingham's claims were procedurally barred under State v. Knaffla. The Supreme Court affirmed, holding the district court did not abuse its discretion when (1) it held that Buckingham's claims were barred under Knaffla, and (2) it denied appellant an evidentiary hearing because the records of the proceeding conclusively showed that Buckingham was not entitled to postconviction relief. View "Buckingham v. State" on Justia Law

Diane Cox was charged with issuing dishonored checks with a value of more than $500 in violation of the dishonored-check statute, which is a felony. Cox filed a motion to dismiss, arguing that the sentencing disparity between the dishonored-check statute and the theft-by-check statute violated her constitutional right to equal protection of the law because issuing a dishonored check is a lesser-included offense of theft-by-check yet is punished more harshly than the greater offense. The district court denied Cox's motion but certified to the court of appeals the question of whether the disparity in the severity of punishment between the two statutes, which arguably contemplate the same acts committed under the same circumstances by persons in like situations, constitutes an equal protection violation as applied to defendant and those similarly charged. The appellate court answered the question in the negative. The Supreme Court affirmed, holding that Cox is not similarly situated to a defendant who commits theft by check because her conduct would not support a conviction for theft by check, and therefore Cox was not denied equal protection of the law. View "State v. Cox" on Justia Law

In district court, appellant was convicted of aiding and abetting first-degree premeditated murder. At issue was whether the district court erred when it denied appellantâs pretrial motion to suppress statements made to law enforcement officials after appellant allegedly invoked his state and federal constitutional rights to remain silent and to have counsel present during custodial interrogation. The Supreme Court affirmed, holding (1) an invocation of the right to remain silent is ambiguous if the suspectâs statement could be interpreted as either a general refusal to answer any questions or as an expression of unwillingness to discuss a specific topic, and (2) when a suspect makes an equivocal invocation of the right to counsel, providing the suspect with a Miranda warning is sufficient as a matter of law to satisfy Minnesotaâs âstop and clarifyâ rule.