Articles Posted in Criminal Law

The Supreme Court held that the decision of the United States Supreme Court in Birchfield v. North Dakota, 579 U.S. __ (2016), and this Court’s decisions in State v. Trahan, 886 N.W.2d 216 (Minn. 2016), and State v. Thompson, 886 N.W.2d 224 (Minn. 2016), announced a new rule of constitutional law that applies retroactively to cases on collateral view. In this consolidated appeal arising from two separate traffic stops, the Supreme Court reviewed the decision of the court of appeals concluding that the Birchfield rule did not apply retroactively to Defendant’s final convictions because the rule was procedural in nature, and that, therefore, the district courts properly denied Defendant’s postconviction petitions. The Supreme Court reversed and remanded to the district court for further proceedings, holding that the Birchfield rule is substantive and applies retroactively to Defendant’s convictions on collateral review. View "Johnson v. State" on Justia Law

The Supreme Court affirmed the decision of the postconviction court denying Appellant’s petition for postconviction relief without an evidentiary hearing, holding that the postconviction court did not abuse its discretion. Appellant was found guilty of first-degree premeditated murder committed for the benefit of a gang. Appellant filed a petition for postconviction relief alleging a witness-recantation claim, ineffective assistance of trial counsel, and a Brady violation. The postconviction court denied the petition without holding an evidentiary hearing. The Supreme Court affirmed, holding that the postconviction court did not abuse its discretion when it summarily denied (1) Appellant’s witness-recantation claim where the evidence presented in support of the claim lacked sufficient indicia of trustworthiness; (2) Appellant’s ineffective assistance of counsel claim because the claim was Knaffla-barred; and (3) Appellant’s Brady-violation claim because the record conclusively showed that Appellant was not entitled to relief. View "Campbell v. State" on Justia Law

The Supreme Court held that a warrantless narcotics-dog sniff in the hallway outside Defendant’s apartment did not violate Defendant’s right to be free from unreasonable searches under the Minnesota and United States Constitutions. A jury found Defendant guilty of first-degree and fifth-degree possession of a controlled substance and possession of a firearm by a prohibited person. The court of appeals reversed the convictions, concluding that the narcotics-dog sniff in the hallway immediately adjacent to Defendant’s apartment door was a search under the Fourth Amendment because it violated Defendant’s reasonable expectations of privacy and that the warrantless search of Defendant’s home was unreasonable. The Supreme Court reversed, holding (1) the police did not intrude upon the curtilage of Defendant’s apartment or his reasonable expectation of privacy when they conducted the dog sniff, and therefore, no Fourth Amendment search occurred; and (2) because the police were lawfully present in the hallway and had a reasonable suspicion of criminal activity, the dog sniff did not violate Minn. Const. art. I, section 10. View "State v. Edstrom" on Justia Law

The Supreme Court held that the classification of a prior offense under Minnesota Sentencing Guidelines 2.B.7.a for the purpose of calculating a defendant’s criminal history score is determined by the Minnesota offense definitions and sentencing policies in effect when the defendant committed the current offense rather than when the defendant is sentenced for the current offense. In 2007, Appellant was convicted of fifth-degree possession of a controlled substance. In March 2016, Appellant committed the current offense of fifth-degree possession of a controlled substance. At that time, the offense was a felony offense. In September 2016, when Appellant was sentenced, the Legislature had reclassified fifth-degree possession of a controlled substance to a gross misdemeanor under certain circumstances. The district court counted the 2007 conviction as a felony in calculating Appellant’s criminal history score. On appeal, Appellant argued that defendants can receive felony criminal history points only for prior felony convictions that are still classified as such at the time of sentencing. The court of appeals disagreed. The Supreme Court affirmed, holding that Appellant’s prior offense was still a felony at the time he committed the current offense, and therefore, Appellant properly received a felony criminal history point. View "State v. Scovel" on Justia Law

The Supreme Court affirmed the decision of the court of appeals upholding Defendant’s conviction of fifth-degree criminal sexual conduct and indecent exposure for sending a picture of his genitals to a minor over Facebook Messenger, holding that Defendant’s simultaneous electronic communications with the minor were sufficient to support his convictions. To be convicted of either crime, Defendant had to exhibit or expose his genitals “in the presence of a minor.” On appeal, Defendant argued that he did not meet the “presence” requirement of the crimes for which he was convicted because he was not physically present with the victim and because he only sent a likeness of his genitals, rather than exposing his actual genitals. The court of appeals affirmed both convictions. The Supreme Court affirmed, holding that Defendant specifically chose to engage in near-simultaneous conversation with the victim and thus used technology to effectively enter the victim’s private room, and therefore, Defendant’s conduct met the statutory requirements to be convicted of the crimes. View "State v. Decker" on Justia Law

The Supreme Court held that Minn. Stat. 609.344(1)(b) and 609.345(1)(b), which prohibit sexual penetration and sexual conduct where the complainant is between thirteen and sixteen years of age and the actor is more than two years older than the complainant, are constitutional even though they prevented Defendant from asserting a mistake-of-age defense. The statutes at issue provide a mistake-of-age defense but only to actors who are no more than 120 months older than the complainant. On appeal, the court of appeals held that the statutes did not violate the guarantees of substantive due process and equal protection under the federal and state constitutions and did not unconstitutionally impose strict liability. The Supreme Court affirmed, holding (1) sections 2609.344(1)(b) and 609.345(1)(b) do not violate substantive due process or equal protection by limiting a mistake-of-age defense to defendants who are no more than 120 months older than the complainant; and (2) the statutes do not impose strict liability but, instead, require proof beyond a reasonable doubt that the actor had a general intent to engage in sexual penetration or sexual contact with the complainant. View "State v. Holloway" on Justia Law

The Supreme Court held that a “school zone,” as defined by Minn. Stat. 152.01(14)(a), includes the entire area of a city block that is situated kitty-corner to school property when the land surrounding the school property is organized in a city-block system. Appellant was convicted of second-degree sale of a controlled substance in a school zone. Appellant filed a petition for postconviction relief arguing that the State had failed to prove that the drug sale at Appellant’s home occurred within 300 feet of school property and, therefore, did not prove that the sale occurred in a school zone. The postconviction court denied the petition, concluding that the entire area of Appellant’s block was included in the school zone. The court of appeals affirmed. The Supreme Court affirmed, holding (1) when the area surrounding school property is organized in a city-block system, as in this case, the school zone, as defined in section 152.01(14)(a)(2), includes the entire area of a city block that is kitty-corner to the school property; and (2) the evidence was sufficient to prove the school-zone element of second-degree sale of a controlled substance in a school zone. View "Lapenotiere v. State" on Justia Law

The Supreme Court affirmed Appellant’s conviction for first- and second-degree murder on an aiding-and-abetting theory. The Court held (1) even if it was error for the district court to admit into evidence Appellant’s statement to police, the error was harmless beyond a reasonable doubt; (2) the district court plainly erred by giving a no-adverse-inference instruction to the jury without Appellant’s consent, but the error was not prejudicial; and (3) assuming, without deciding, that the prosecutor committed misconduct during closing argument by “indirectly alluding” to Appellant’s failure to testify, the prosecutor’s argument was not prejudicial. View "State v. Johnson" on Justia Law

The Supreme Court affirmed in part and reversed and remanded in part the postconviction court’s denial of Petitioner’s second petition for postconviction relief without holding an evidentiary hearing. Petitioner was found guilty of first-degree premeditated murder and sentenced to life in prison without the possibility of release. After his first postconviction petition was summarily denied, Petitioner filed his second postconviction petition, alleging the existence of sixteen pieces of newly discovered evidence. The postconviction court denied the second petition without holding an evidentiary hearing, concluding that the petition was untimely because the facts alleged in the petition did not satisfy the statutory newly-discovered-evidence exception. The Supreme Court reversed in part, holding (1) the postconviction court abused its discretion by making improper credibility determinations without holding an evidentiary hearing; and (2) the facts alleged in support of Petitioner’s remaining claims did not satisfy the newly-discovered-evidence or interests-of-justice exceptions to the two-year statute of limitations. View "Anderson v. State" on Justia Law

The Supreme Court affirmed the postconviction court’s denial of Petitioner’s petition for postconviction relief, holding that the postconviction court did not abuse its discretion. Petitioner was found guilty of first-degree premeditated murder and first-degree felony murder. Petitioner was sentenced to life imprisonment without the possibility of release for the murder conviction. The Supreme Court affirmed. Petitioner later filed a petition for postconviction relief, alleging six grounds for postconviction relief. The postconviction court rejected the petition without holding an evidentiary hearing. The Supreme Court affirmed, holding that Petitioner’s claims were either procedurally barred or failed as a matter of law. View "Fox v. State" on Justia Law