Justia Minnesota Supreme Court Opinion Summaries

The State charged Larry Joe Foster with second-degree intentional murder for the death of Daniel Bradley. Foster claimed that another person, R.J., committed the murder. The district court determined that Foster met the requirements to present an alternative perpetrator defense and allowed him to introduce evidence supporting his claim. Foster intended to call R.J. as a witness, but R.J. invoked his right against self-incrimination before the trial. Foster requested that R.J. be required to invoke this right in front of the jury, but the district court denied the request, citing the lack of probative value and the cumulative nature of the evidence.The jury found Foster guilty of second-degree murder. Foster appealed, arguing that the district court violated his constitutional rights by not allowing him to call R.J. to the stand. The Minnesota Court of Appeals affirmed Foster’s conviction, concluding that he had no constitutional right to call R.J. solely to invoke his right against self-incrimination.The Minnesota Supreme Court reviewed the case and held that when a defendant has satisfied the required test to present an alternative perpetrator defense, the district court has discretion to allow the defendant to call the alternative perpetrator as a witness, even if it is known that the alternative perpetrator will invoke their right against self-incrimination. However, the district court must apply the ordinary rules of evidence in making this determination. The Supreme Court concluded that the district court did not abuse its discretion in denying Foster’s request, as the invocation of the right against self-incrimination by R.J. would have been needlessly cumulative. The decision of the court of appeals was affirmed on different grounds. View "State v. Foster" on Justia Law

In 2002, Fred Williamson was fatally shot while in a car in Minneapolis. B.H., a passenger in Williamson's car, initially claimed he did not see the shooter. Later, B.H. was indicted on unrelated federal drug charges and agreed to provide substantial assistance in Williamson's murder investigation in exchange for a potential sentence reduction. At trial, B.H. identified Leroy Roderick Paul as the shooter. Paul was convicted of first-degree murder during a drive-by shooting and sentenced to life in prison. His conviction was affirmed on direct appeal.Paul filed a petition for postconviction relief in 2023, claiming the State violated Brady v. Maryland and Giglio v. United States by not disclosing the specific terms of B.H.'s plea agreement. The district court denied the petition without an evidentiary hearing, finding no factual support for Paul's claim and determining the petition was untimely under the two-year statutory time bar.The Minnesota Supreme Court reviewed the case and affirmed the district court's decision. The court held that the evidence presented by Paul, even if accepted as true, did not support his claim that B.H. had negotiated a specific sentence. The court also found that Paul's petition was untimely and did not meet the exceptions for newly discovered evidence or interests of justice. The court concluded that the district court did not abuse its discretion in summarily denying the petition. View "Paul v. State" on Justia Law

Eloisa Rubi Plancarte was convicted of misdemeanor indecent exposure under Minnesota Statutes section 617.23, subdivision 1(1) for exposing her breasts in a gas station parking lot. Plancarte argued that her breasts are not "private parts" under the statute and that her exposure was not "lewd." She also claimed that prosecuting her for conduct that men are allowed to engage in violated her constitutional right to equal protection. The district court denied her motion to dismiss, and she was found guilty in a stipulated-evidence trial.Plancarte appealed her conviction, but the court of appeals affirmed it in a divided opinion. The majority concluded that the evidence was sufficient to support the conviction, while the dissent argued that the statute requires lewd conduct in addition to exposure, which was not proven in this case.The Minnesota Supreme Court reviewed the case and concluded that the term "lewdly" in the statute refers to conduct of a sexual nature. The court found that the State did not present sufficient evidence to prove that Plancarte's exposure was lewd, as there was no indication that her conduct was of a sexual nature. Consequently, the court reversed Plancarte's conviction. The court did not address whether female breasts are "private parts" under the statute or the equal protection claim, as the decision on the lewdness element resolved the case. View "State v. Plancarte" on Justia Law

Henry Lee Brown was involved in a fatal collision in 2021 while driving near his home in Minneapolis. After hitting and killing a pedestrian, Brown did not stop at the scene and drove home without notifying the police. He was charged with two counts of criminal vehicular homicide, including leaving the scene of a collision. Brown initially pled not guilty but later changed his plea to guilty for leaving the scene after causing the collision. He admitted to driving the vehicle and leaving the scene but claimed he was unconscious at the time of the collision due to a medical incident.The district court denied Brown's motion to withdraw his guilty plea and sentenced him to 58 months in prison. Brown appealed, arguing that the statute required the State to prove he was volitionally operating the vehicle at the time of the collision. The court of appeals affirmed the district court's decision, holding that the statute did not require volitional operation at the time of the collision.The Minnesota Supreme Court reviewed the case to determine whether the criminal vehicular homicide statute required proof of volitional operation at the time of the collision. The court concluded that the statute does not require an act of operation at the time of the collision. Instead, an act of operating a motor vehicle that takes place before a collision can satisfy the statute's requirements. The court affirmed the decision of the court of appeals on other grounds, holding that Brown's factual basis for his guilty plea was adequate because he admitted to volitionally operating the vehicle before losing consciousness, causing the pedestrian's death, and leaving the scene without returning. View "State v. Brown" on Justia Law

A Nashwauk police officer observed a vehicle swerving and initiated a traffic stop, identifying the driver as Christopher Lee Manska. The officer noted signs of intoxication and discovered Manska's driver's license had been canceled. Manska refused a chemical test, and a search of his vehicle revealed marijuana. He was charged with multiple offenses, including driving while impaired and possession of marijuana. Manska sought the audit trail of the dash camera footage, claiming the footage had been tampered with.The district court denied Manska's motion to compel the audit trail, finding his claims of tampering unsupported and not credible. The court of appeals affirmed, concluding that Manska failed to show the information sought would be "material and favorable" to his defense, applying a higher standard than required.The Minnesota Supreme Court reviewed the case, determining that the lower courts applied the wrong standard. The correct standard under Minn. R. Crim. P. 9.01, subd. 2(3), requires only that the information sought "may relate to the guilt or innocence of the defendant." The Supreme Court concluded that Manska made an adequate showing that the audit trail may relate to his guilt or innocence, as it could reveal discrepancies in the dash camera footage that would challenge the officer's credibility.The Supreme Court reversed the lower courts' decisions and remanded the case. On remand, the district court must require the State to disclose the audit trail. If the audit trail shows tampering, Manska is entitled to a new suppression hearing. If no tampering is found, the conviction stands. View "State v. Manska" on Justia Law

In 2021, Ryan Martens disclosed to his therapist that he had engaged in sexual contact with his children's babysitter when she was 17 years old. The therapist, a mandated reporter, filed a maltreatment report with Kanabec County authorities. At the time of the disclosure, the victim was 18 years old. Martens was subsequently charged with third-degree criminal sexual conduct.The district court denied Martens's motion to exclude the therapist's report and testimony, ruling that the therapist-client privilege did not apply because the report was mandatory under the mandated-reporter statute. A jury found Martens guilty, and the court of appeals affirmed the conviction, concluding that the mandated-reporter statute required the therapist to file the report.The Minnesota Supreme Court reviewed the case to determine whether the mandated-reporter statute, Minn. Stat. § 260E.06, subd. 1(a), requires a report when the maltreated child is over 18 at the time of disclosure. The court held that the statute mandates a report if the reporter knows or has reason to believe that a child has been maltreated within the preceding three years, even if the child reaches adulthood before the disclosure. Consequently, the court affirmed the lower court's decision, ruling that the district court did not err in admitting the therapist's report and testimony. View "State of Minnesota vs. Martens" on Justia Law

A deputy from the Ramsey County Sheriff’s Department stopped Kyaw Be Bee’s vehicle on a public roadway in Saint Paul and found a BB gun under the driver’s seat. Bee was charged with carrying a BB gun in a public place, a gross misdemeanor under Minn. Stat. § 624.7181, subd. 2 (2024). The statute defines “public place” to include property owned or controlled by a governmental unit and private property open to the public, excluding certain private properties and specific locations.The district court dismissed the complaint for lack of probable cause, ruling that the interior of a motor vehicle on a public roadway is not a “public place” under the statute. The State appealed, and the Minnesota Court of Appeals reversed the district court’s decision. The appellate court held that the term “public place” unambiguously includes the interior of a motor vehicle on a public roadway, referencing the statutory context and a related exemption for transporting firearms in vehicles.The Minnesota Supreme Court reviewed the case to determine whether the interior of a private motor vehicle on a public road is a “public place” under Minn. Stat. § 624.7181, subd. 1(c). The court concluded that the term “public place” unambiguously includes the interior of a motor vehicle on a public roadway. The court reasoned that the statute’s exemptions and related provisions indicate that a motor vehicle on a public road is considered a public place. Consequently, the Supreme Court affirmed the decision of the court of appeals, reinstating the charge against Bee. View "State of Minnesota vs. Bee" on Justia Law

In 2018, Joshua Chiazor Ezeka was convicted by a Hennepin County jury of first-degree premeditated murder, first-degree attempted murder, and second-degree assault for killing Birdell Beeks while shooting at a rival gang member. He was sentenced to life in prison without the possibility of release for the murder, and additional consecutive sentences for the other charges. On direct appeal, the Minnesota Supreme Court affirmed his convictions but remanded for resentencing on the attempted murder charge due to an excessive sentence.After resentencing, Ezeka filed a petition for postconviction relief in 2022, which the district court denied without an evidentiary hearing. The district court concluded that even if the facts alleged in the petition were proven, Ezeka was not entitled to relief. The court also found that most of his claims were procedurally barred as they were known or should have been known at the time of his direct appeal.The Minnesota Supreme Court reviewed the case and affirmed the district court's decision. The court held that the new evidence presented by Ezeka, including reports of general discriminatory practices by the Minneapolis Police Department and the Hennepin County Attorney’s Office, did not meet the legal standard for newly discovered evidence as it did not directly pertain to his case and would not have changed the trial's outcome. The court also found that the alleged failure to disclose this evidence did not constitute a Brady violation as it was not material to the case.Additionally, the court rejected Ezeka’s claims of ineffective assistance of trial and appellate counsel, concluding that his trial counsel’s performance was not objectively unreasonable and that there was no prejudice resulting from the alleged deficiencies. The court determined that the district court did not abuse its discretion in summarily denying the petition for postconviction relief. View "Ezeka vs. State of Minnesota" on Justia Law

Edgard Francisco Talave Latino was charged with misdemeanor domestic assault after an incident with M.T.L., with whom he had a prior romantic and sexual relationship. Latino and M.T.L. met in 2020 and had an on-again, off-again relationship that ended in November 2021. Shortly after their breakup, Latino went to M.T.L.'s apartment, where an argument ensued, and he assaulted her.The district court found Latino guilty of misdemeanor domestic assault, determining that he and M.T.L. had been involved in a significant romantic or sexual relationship, thus meeting the statutory definition of "family or household member." Latino waived his right to a jury trial, and the district court made this finding based on the evidence presented.Latino appealed, arguing that the statutory definition of "family or household member" should only apply to current relationships, not former ones. The Minnesota Court of Appeals disagreed, affirming the conviction by referencing its decision in Sperle v. Orth, which held that former relationships could qualify under the statute. The court of appeals concluded that the evidence was sufficient to prove that Latino and M.T.L. had been in a significant romantic or sexual relationship.The Minnesota Supreme Court reviewed the case to determine whether the statutory definition of "family or household member" includes former significant romantic or sexual relationships. The court held that the definition does include former relationships, subject to the statutory factors of length, type, frequency of interaction, and time since termination. The court found that the evidence was sufficient to support the district court's finding that Latino and M.T.L. had been involved in such a relationship, affirming the decision of the court of appeals. View "State vs. Talave Latino" on Justia Law

Berry Alexander Davis was involved in the kidnapping and murder of Monique Baugh and the attempted murder of her boyfriend, Jon, on New Year’s Eve in 2019. Baugh was abducted, placed in a U-Haul truck, and fatally shot. Davis and a co-defendant, Cedric Lamont Berry, were charged with first-degree premeditated murder, attempted first-degree premeditated murder, and kidnapping. The State's theory was that Davis and Berry attacked Jon on behalf of Lyndon Wiggins, who had a falling out with Jon. Detective Briana Johnson testified about the relationship between Davis, Berry, and Wiggins, indicating they were involved in drug dealing together. Davis waived his right to testify, and the jury found him guilty on all counts. He was sentenced to life in prison without the possibility of release.On direct appeal, Davis argued that the district court erred in joining his trial with Berry’s and that Detective Johnson’s testimony was inadmissible and prejudicial. The Minnesota Supreme Court rejected these arguments and affirmed his conviction and sentence. Davis also filed a pro se supplemental brief raising several claims, including that his sentence violated his constitutional right to a sentencing jury under Blakely v. Washington. The court found these claims lacked merit.Davis subsequently filed a postconviction petition alleging ineffective assistance of trial and appellate counsel and constitutional violations in his sentencing. The district court summarily denied the petition without an evidentiary hearing, concluding that even if Davis proved the facts alleged, he would not be entitled to relief as a matter of law.The Minnesota Supreme Court reviewed the case and affirmed the district court’s decision. The court held that the district court did not abuse its discretion in denying Davis’s postconviction petition without an evidentiary hearing, as his claims failed on their merits as a matter of law. View "Davis vs. State" on Justia Law