Articles Posted in Criminal Law

The Supreme Court affirmed in part and reversed in part the judgment of the court of appeals ruling that Minnesota’s vehicle forfeiture statute, Minn. Stat. 169A.63, is unconstitutional as applied to Helen and Megan Olson, holding that the statute is constitutional on its face and constitutional as applied to Megan but unconstitutional as applied to Helen. Megan was arrested for driving while impaired (DWI) and was subject to being charged with a first-degree DWI offense. Because a first-degree DWI offense is a “designated” offense under the DWI vehicle forfeiture statute, the vehicle Megan was driving when she was arrested - a 1999 Lexus owned by Megan’s mother Helen - was subject to forfeiture. The police seized the vehicle incident to Megan’s lawful arrest. The Olsons filed a demand for judicial determination of the forfeiture, arguing that section 169A.63(9)(d), which sets forth the procedural requirements for judicial hearings related to vehicle forfeiture for a DWI offense, violated their due process rights. The district court determined that the statute was unconstitutional on its face. The court of appeals affirmed on different grounds. The Supreme Court held that the statute was constitutional as applied to Megan, who did not own the vehicle, but unconstitutional as applied to Helen, the purportedly innocent owner. View "Olson v. One 1999 Lexus" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the district court determining that the physician-patient privilege covered a blood sample and granting Defendant’s motion to suppress the results of a blood-alcohol concentration test derived from the blood sample, holding that a blood sample is not covered by the physician-patient privilege. The blood sample in this case was drawn by a medical professional during the course of emergency medical treatment after Defendant was injured in an ATV accident. In reversing the district court’s decision to suppress the evidence, the court of appeals concluded that a blood sample does not fall within the plain meaning of the word “information” as used in Minnesota’s statutory physician-patient privilege, codified at Minn. Stat. 595.02(1)(d). The Supreme Court affirmed, holding holding that the word “information” as used in the statute does not include a blood samples, and therefore, the physician-patient privilege did not apply to Defendant’s blood sample and the results of the blood-alcohol concentration test derived from the blood sample. View "State v. Atwood" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the district court’s denial of Appellant’s request for a jury instruction on the defense of voluntary intoxication, holding that Minn. State. 617.23(2), the indecent-exposure statute, does not require the State to prove that the defendant had a specific intent to be lewd. Defendant was charged with indecent exposure in the presence of a minor under the age of sixteen. After concluding that the indecent-exposure statute creates a general-intent crime, the district court denied Defendant’s request that the jury be instructed on the defense of voluntary intoxication because that defense only applies to specific-intent crimes. The jury found Defendant guilty. The court of appeals affirmed. The Supreme Court affirmed, holding that the offense of indecent exposure is a general-intent crime, and therefore, the court of appeals did not err when it affirmed the district court’s denial of Defendant’s request for a jury instruction on the defense of voluntary intoxication. View "State v. Jama" on Justia Law

The Supreme Court affirmed the decision of the postconviction court summarily denying Appellant’s present petition for postconviction relief, holding that the record conclusively established that Appellant was not entitled to relief. Appellant was convicted of aiding and abetting first-degree felony murder. After the conviction was affirmed on direct appeal, Appellant filed three petitions for postconviction relief, each of which was summarily denied. At issue int his appeal was Appellant’s fourth petition for postconviction relief, which the postconviction court denied without an evidentiary hearing. The Supreme Court affirmed, holding that Appellant was not entitled to relief on any of his claims. View "Crow v. State" on Justia Law

The Supreme Court affirmed Defendant’s convictions but reversed his sentence for first-degree murder of an unborn child, holding that the plain language of Minn. Stat. 609.106 does not authorize a sentence of life imprisonment without the possibility of release for a conviction of first-degree murder of an unborn child. Defendant was convicted of first-degree premeditated murder and first-degree premeditated murder of an unborn child. The Supreme Court upheld the convictions but reversed Defendant’s life sentence, holding (1) structural error did not occur when the district court judge presided over Defendant’s jury trial after defense counsel commented during an ex parte conversation that Defendant might commit perjury; (2) Defendant received effective assistance of counsel; (3) the district court did not commit plain error in its jury instructions; and (4) Defendant’s sentence of life imprisonment without the possibility of release for his conviction of first-degree murder of an unborn child was not authorized by section 609.106. View "State v. Mouelle" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing the district court’s denial of Defendant’s motion to correct his sentence, holding that the two-tier conditional-release term contained in Minn. Stat. 617.247, subd. 9, the child pornography statute, is not ambiguous and was properly applied in this case. Defendant pleaded guilty to one count of possessing child pornography. Relying on Minn. Stat. 617.247, subd. 9, the district court imposed a conditional-release term of ten years in addition to a twenty-month term of incarceration. In his motion to correct his sentence, Defendant argued that the proper term of conditional release was five years. The district court denied the motion. The court of appeals reversed and vacated Defendant’s conditional-release term, concluding that the statute contained a “temporal ambiguity” and that Defendant’s sentence was not authorized by law. The Supreme Court reversed, holding that section 617.247, subd. 9 is unambiguous and requires a ten-year conditional-release term for Defendant. View "State v. Overweg" on Justia Law

The Supreme Court affirmed the decision of the court of appeals upholding Defendant’s conviction of simple robbery, holding that the evidence was sufficient to support the conviction. Defendant’s conviction arose from his act of taking a bottle of brandy from a liquor store and assaulting the store manager. On appeal, Defendant argued that he could not be convicted of simple robbery because the bottle that he took belonged to the business and not to a person, and therefore, the property was not “personal property” within the meaning of Minn. Stat. 609.24. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the phrase “personal property” as used in the statute is a technical term that has acquired the specialized meaning of all property other than real property; and (2) therefore, the evidence was sufficient to support the conviction. View "State v. Bowen" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming Appellant’s conviction of felony domestic assault, holding that the evidence was sufficient to prove that Defendant and the victim were “persons involved in a significant romantic or sexual relationship” at the time of the offense under Minn. Stat. 609.2242(4). In affirming, the court of appeals concluded that the phrase “significant romantic or sexual relationship” is unambiguous. The Supreme Court affirmed, holding (1) that to determine whether two persons are involved in a “significant romantic or sexual relationship” for the purposes of the domestic-assault statute, a court must undergo a case-by-case analysis using the statutory factors of Minn. Stat. 518B.01(2), including the length of the relationship, the type of relationship, and the frequency of interactions between the two persons; and (2) the record was sufficient to support the jury’s finding that Defendant and the victim were in a “significant romantic or sexual relationship” when the assault occurred. View "State v. Robinson" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of first-degree premeditated murder and sentencing him to life in prison without the possibility of release, holding that, contrary to Defendant's assertions on appeal, Defendant’s conviction was not based on corroborated accomplice testimony and that there was no abuse of discretion in the jury instructions. Specifically, the Court held (1) the testimony of Defendant’s accomplice was sufficiently corroborated, and therefore, Defendant’s premeditated murder conviction did not violate Minn. Stat. 634.04; and (2) the district court did not abuse its discretion when it denied Defendant’s request to instruct the jury about the credibility of drug users or witnesses who could later be charged as accessories after the fact. View "State v. Thoresen" on Justia Law

The Supreme Court reversed the court of appeals affirming the district court’s competency determination in this criminal case, holding that the court of appeals erred when it did not follow State v. Ganpat, 732 N.W. 2d 232 (Minn. 2007), and place the burden of proving that Defendant was competent on the State. After determining that Defendant was mentally competent to proceed to trial, the district court convicted him of fourth-degree criminal sexual conduct. Defendant appealed, arguing that the district court failed to place the burden of proof on the State as required by Ganpat in determining him to be competent. In affirming, the court of appeals declined to follow Ganpat, instead ruling that competency should be determined based on the greater weight of the evidence without regard to burden of proof. The Supreme Court reversed and remanded, holding that the court of appeals and district court erred in failing to adhere to Ganpat and that it was not certain whether the district court would have made the same competency determination had it applied the correct burden of proof. View "State v. Curtis" on Justia Law