Articles Posted in Criminal Law

The Supreme Court reversed the decision of the court of appeals holding that Minn. Stat. 609.342(1)(h) does not require the State to prove that “sexual penetration” occurred, holding that the plain language of the statute requires proof of “sexual penetration," and therefore, the State presented insufficient evidence to support Defendant's conviction. Defendant was convicted of first-degree criminal sexual conduct under section 609.342(1)(h) for engaging in genital-to-genital contact with G.M. On appeal, Defendant argued that the State presented insufficient evidence to support the conviction because the statute requires proof of “sexual penetration” and the State did not prove sexual penetration. The court of appeals rejected Defendant’s argument and affirmed. The Supreme Court reversed and remanded to the district court for further proceedings, holding that the plain language of subdivision 1(h) unambiguously requires proof of sexual penetration. View "State v. Ortega-Rodriguez" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the decision of the postconviction court that Defendant was entitled to a new trial because a juror was actually biased and not sufficiently rehabilitated but that the search of Defendant did not violate his Fourth Amendment rights. Defendant was convicted of possession of a firearm by an ineligible person. Thereafter, Defendant filed a postconviction petition arguing that the district court erred in denying his for-cause strike of Juror 18 and that the police unreasonably searched and seized him, violating his Fourth Amendment rights. The postconviction court rejected Defendant’s Fourth Amendment argument but concluded that the district court committed reversible error by denying the motion to strike Juror 18 for cause. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the search of Defendant was objectively reasonable under the emergency-aid exception to the Fourth Amendment warrant requirement; and (2) Defendant was entitled to a new trial because the presence of the actually biased juror. View "Ries v. State" on Justia Law

The Supreme Court affirmed the decision of the district court denying Appellant’s motion to correct his sentences under Minn. R. Crim. P. 27.03(9), holding that the district court did not commit reversible error. Appellant was convicted of murdering his ex-wife and kidnapping their three children. The Supreme Court affirmed Appellant’s convictions and sentences. Appellant later filed the present motion to correct his sentences. Relying on Minn. Stat. 611.02, 609.04 and 609.035, Appellant argued that the district court committed reversible error. The district court denied the motion without holding a hearing. The Supreme Court affirmed, holding (1) Appellant’s claims made under Minn. Stat. 609.04 and 611.02 challenging his convictions were outside the scope of Rule 27.03(9); and (2) Appellant’s sentences did not violate section 609.035. View "Munt v. State" on Justia Law

The Supreme Court affirmed the postconviction court’s summary denial of Defendant’s second postconviction petition, holding that the record conclusively showed that Defendant was not entitled to relief. Defendant was convicted of first-degree premeditated murder. The Supreme Court affirmed. This appeal concerned the postconviction court’s summary denial of Defendant’s second petition for postconviction relief in which Defendant argued that he was entitled to relief under the newly-discovered-evidence or interests-of-justice exceptions to the two-year statute of limitations governing postconviction petitions. The Supreme Court affirmed, holding that the postconviction court did not abuse its discretion in summarily denying the petition because (1) certain claims did not satisfy the interests-of-justice exception to the statute of limitations, (2) other claims were untimely, and (3) the remaining claims were unsupported by arguments or legal authority. View "Nissalke v. State" on Justia Law

The Supreme Court affirmed the postconviction court’s denial of Appellant’s petition for postconviction relief challenging his conviction for first-degree murder for the benefit of a gang, holding that Appellant’s claims were procedurally barred by the rule articulated in State v. Knaffla, 243 N.W.2d 737, 741 (Minn. 1976). The postconviction court found that Appellant was not entitled to relief because his claims were procedurally barred by the Knaffla rule. The Supreme Court affirmed, holding that because Appellant’s postconviction petition was based on claims that were raised and decided in previous proceedings, the postconviction court did not abuse its discretion when it summarily denied the petition. View "Jackson v. State" on Justia 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