Justia Minnesota Supreme Court Opinion Summaries

Appellant Dario Bonga pled guilty to first-degree premeditated murder less than one day after he confessed to killing Carlos San Miguel and attempted to kill himself while in custody awaiting trial. The district court accepted Appellantâs guilty plea, convicted him, and sentenced him to life in prison. Appellant filed a petition for post conviction relief in which he sought to withdraw his guilty plea, arguing that he was not competent to plead guilty. On appeal to the Supreme Court, Appellant argued that the district court did not give sufficient weight to evidence that suggested he was incompetent to plead when it sentenced him to life. Particularly, Appellant argued that the court should have ordered an examination and report on Appellantâs mental condition when it learned that Appellant attempted suicide the day before the hearing. The Supreme Courtâs review of the record revealed that on several occasions Appellant was offered counsel, dismissed counsel, sought to speak with the prosecutors, and asked to represent himself at trial. The record would also reveal that the trial court asked Appellant multiple times, on the record, whether he understood the nature of the charges against him and whether Appellant understood the risk he ran by representing himself. The Court was satisfied that the trial court gave Appellant every opportunity to seek counsel and preserve his legal rights. Finding no error, the Supreme Court affirmed Appellantâs conviction and sentence.

A Hennepin County grand jury indicted Appellant Gary Vue with several gang-related felonies. A jury found Appellant guilty, and the district court convicted him and imposed a life sentence with the possibility of parole after 31 years. Appellant appealed his conviction, claiming that the district court erroneously admitted his statement to the police, and that the evidence presented at trial was insufficient to convict him. In December, 2005, police received a tip on the whereabouts of Appellant and his brother who were both suspects in the shooting death of Za Xiong. The tip lead police to Appellant then living in Sacramento, California. The police went to Sacramento to interview him. Within eight minutes, Appellant confessed to the shooting. Police did not believe they had the authority to arrest Appellant outside their jurisdiction. They returned to Hennepin County and got an arrest warrant for the brother. Three years later, in March, 2009, police were able to apprehend Appellant in St. Paul. Appellant pled not guilty, and sought to exclude his statements made to police while in Sacramento. The district court denied Appellantâs motion to suppress, concluding that Appellant was not in custody and, therefore, the police were not required legally to advise him of his Miranda rights. The Supreme Court held that the lower court was correct to deny Appellantâs motion to suppress his statement to the police in Sacramento. Furthermore, it found that the evidence presented at trial was sufficient to allow a rational trier of fact to convict him of the gang-related felonies. The Court accordingly affirmed Appellantâs conviction.