Justia Minnesota Supreme Court Opinion Summaries

The Supreme Court reversed the opinion of the court of appeals reversing Defendant's convictions for driving after cancellation-inimical to public safety (DAC-IPS) based on the conclusion that Minn. Stat. 171.24, subd. 5 is unenforceable on private property, holding that the statute is enforceable on private property.Defendant, whose license was cancelled as inimical to public safety, was charged with DAC-IPS after a law enforcement officer observed him drive a motor vehicle down a private driveway. Defendant filed a motion to suppress and to dismiss the complaint for lack of probable cause. The district court denied the motions. The district court subsequently found Defendant guilty. The court of appeals reversed, ruling that the DAC-IPS requires a license only when a vehicle is operated on a street or highway. The Supreme Court reversed, holding (1) the DAC-IPS statute is enforceable in private property; and (2) the district court properly denied Defendant's motions to suppress and dismiss, resulting in restatement of Defendant's convictions. View "State v. Velisek" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals granting the petition for a writ of prohibition filed by the State prohibiting the district court from enforcing a "taint team" order, holding that the district court erred in concluding that the Sixth Amendment right to counsel was implicated in this case.Appellant, a juvenile at the time of his offense, was convicted of first-degree premeditated murder and sentenced to two consecutive sentences of life without the possibility of release. After Miller v. Alabama, 467 U.S. 460 (2012), was decided, Appellant was granted resentencing. At issue during the hearing was copies of recorded calls made by Appellant while he was incarcerated. The district court ordered the State to use a taint team to review the recorded calls for attorney-client communications on the ground that Appellant's the constitutional right to counsel was implicated. The court of appeals granted the State's petition for a writ prohibiting the court from enforcing the taint team order. The Supreme Court affirmed, holding that relief was not warranted because (1) the Sixth Amendment was not implicated here; and (2) the State would be injured and without any adequate remedy to correct the unauthorized action of the court. View "State v. Flowers" on Justia Law

The Supreme Court affirmed the judgment of the district court dismissing this lawsuit brought by Appellants seeking a declaration "that individuals are restored to civil rights and possess the fundamental right to vote guaranteed by [Minn. Const. art. VII] by virtue of being released or excused from incarceration following a felony," holding that there was no error.At issue before the Supreme Court was (1) whether Minn. Const. art. VII, 1 requires that a person convicted of a felony be restored to the right to vote upon being released or excused from incarceration; and (2) whether Minn. Stat. 609.165 is contrary to the fundamental right to vote or to equal protection protections under the state Constitution. The Supreme Court held (1) under article VII, section 1, a person convicted of a felony cannot vote in Minnesota unless his or her right to vote is restored in accordance with an affirmative act or governmental mechanism restoring the person's right to vote; and (2) section 609.165 does not violate the fundamental right to vote, and there was insufficient evidence to prove that the statute violates the Minnesota Constitution's equal protection principle. View "Schroeder v. Simon" on Justia Law

The Supreme Court affirmed the opinion of the court of appeals affirming the decision of the district court to allow a witness to testify using live, two-way remote view technology during a jury trial in the midst of the COVID-19 pandemic, holding that Defendant's right to confrontation was not violated in the proceedings below.During Defendant's jury trial on a third-degree sale of a controlled substance charge, the district court allowed one of the State's witness to testify via Zoom because she had been exposed to COVID-19 and was forced to quarantine. Defendant appealed. The Supreme Court affirmed, holding (1) the two-part test set forth in Maryland v. Craig, 497 U.S. 836 (1990), is the appropriate test to assess whether a Confrontation Clause violation under the federal or state constitutions; and (2) Defendant's right to confrontation under the federal and state constitutions when the district court permitted the witness to testify using remote view technology under the circumstances of this case. View "State v. Tate" on Justia Law

In this dispute over Governor Walz's declaration of a peacetime emergency under the Emergency Management Act, Minn. Stat. 12.01-.61, and the executive order the Governor issued requiring that Minnesotans wear face coverings, the Supreme Court affirmed in part and reversed in part the judgment of the court of appeals dismissing the appeal as moot, holding that one issue on appeal met a mootness exception.Plaintiffs brought the underlying petition for a writ of quo warranto challenging the face-covering mandate, arguing that the Governor overstepped his powers under the Emergency Management Act and that the mask mandate violated several of their constitutional rights. The district court granted Defendants' motion to dismiss. While Plaintiffs' appeal was pending, the peacetime emergency and mask mandate ended. Consequently, the court of appeals dismissed the appeal as moot. The Supreme Court reversed in part, holding (1) the legal question of whether the Act authorizes a peacetime emergency for a public health emergency is functionally justiciable and an important issue of statewide significance that should be decided immediately; and (2) Plaintiffs' remaining challenges to the mask mandate did not meet any of the mootness exceptions. View "Snell v. Walz" on Justia Law

The Supreme Court affirmed the judgment of the district court summarily denying Defendant's second petition for postconviction relief, holding that the district court did not abuse its discretion in denying the petition without holding an evidentiary hearing.After a jury trial, Defendant was found guilty of first-degree felony murder and attempted first-degree premeditated murder, among other crimes. Defendant later filed the postconviction petition at issue, asserting that he was denied his Sixth Amendment right to a trial before an impartial jury and that his trial counsel and appellate counsel provided ineffective assistance. The district court summarily denied the petition as time barred and procedurally barred. The Supreme Court affirmed, holding that the district court did not abuse its discretion when it summarily denied Defendant's second postconviction petition as untimely. View "White v. State" on Justia Law

The Supreme Court affirmed Defendant's convictions for first-degree premeditated murder, attempted first-degree murder, and kidnapping, holding that there was no error in the proceedings below.On appeal, Defendant argued, among other things, that the district court erroneously joined his and his codefendant's cases for trial and by denying subsequent severance motions. The Supreme Court affirmed his convictions, holding (1) the district court did not improperly join Defendant's and his codefendant's cases for trial and did not erroneously refuse to sever the cases once the trial was underway; (2) the prosecutor did not commit misconduct during closing arguments; and (3) Defendant was not entitled to relief as to the claims he raised in a pro se supplemental brief. View "State v. Davis" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the district court's decision to grant summary judgment in favor of Cornelius Emily and Earnest Rhoney, Department of Corrections officers, and dismiss Plaintiff's claims of cruel and unusual punishment, holding that Plaintiff's 42 U.S.C. 1983 claim survived summary judgment.Plaintiff, who was incarcerated in the Stillwater correctional facility, suffered serious injury in both of his wrists when Officers Emily and Rhoney improperly applied overtightened handcuffs on Plaintiff for three and one-half hours. Plaintiff brought this action seeking damages. The district court granted summary judgment, concluding that the officers did not act maliciously or sadistically. The court of appeals reversed. The Supreme Court affirmed, holding (1) the conduct of the officers should be assessed under the deliberate indifference standard applicable to conditions of confinement and medical care; and (2) qualified immunity did not bar Plaintiff's deliberate indifference claim. View "Welters v. Minn. Dep't of Corrections" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the district court granting Defendant's motion to dismiss the charge of fifth-degree marijuana possession against him for lack of probable cause, holding that the evidence was sufficient to survive a motion to dismiss for lack of probable cause.This case arose when law enforcement officers discovered a plant substance in Defendant's car during a traffic stop. While the State did not test the concentration of THC in the substance before charging gate case, a field test of the substance detected the presence of THC. The district court granted Defendant's motion to dismiss for lack of probable cause. The court of appeals reversed, concluding that chemical testing establishing the THC concentration of substance was not required when there is other sufficient evidence to support a probable cause finding. The Supreme Court affirmed, holding that Defendant's admission that the material in the vehicle was marijuana was sufficient to survive a motion to dismiss the charge of fifth-degree marijuana possession. View "State v. Dixon" on Justia Law

The Supreme Court held that, for double jeopardy purposes, the unit of prosecution for a violation of Minn. Stat. 243.166, subd. 3(a), which requires a predatory offender to register "with the corrections agent as soon as the agent is assigned to the person," is the assignment of a corrections agent, thus affirming in part and reversing in part the decision of the court of appeals.Defendant was convicted and sentenced on seven separate occasions between 2004 and 2018 for failing to register under subdivision 3(a). In August 2019, Defendant refused to sign required paperwork presented by his new corrections agent. In September 2019, Defendant again refused to sign the paperwork presented by a special agent of the Minnesota Bureau of Criminal Apprehension assigned by Defendant's corrections agent. The State charged Defendant with two counts of failing to register under subdivision 3(a). Defendant moved to dismiss the charges on double jeopardy grounds. The district court denied the motion, and the court of appeals affirmed. The Supreme Court reversed in part, holding (1) Defendant's earlier convictions did not bar prosecution of the August 2019 offense; but (2) the September 2019 offense was barred. View "State v. Larson" on Justia Law