Articles Posted in Criminal Law

The Supreme Court affirmed Defendant's conviction for first-degree premeditated murder but reversed Defendant's conviction for second-degree intentional murder, holding that the district court improperly entered a conviction on both first-degree and second-degree murder. Specifically, the Court held (1) the district court did not abuse its discretion by admitting the recorded statement of an eyewitness under Minn. R. Evid. 807 even after the witness partially recanted the statement at trial; (2) the district court did not abuse its discretion by admitting the evidence of the contents of a backpack linking Appellant to items that went missing with the murder weapon; (3) the district court erred by entering a conviction for both first-degree and second-degree murder because second-degree intentional murder is a lesser-included offense of first-degree premeditated murder; and (4) none of Appellant's pro se claims had merit. View "State v. Hallmark" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing Defendant's conviction of burglary in the first degree and criminal sexual conduct in the fourth degree on the ground that the district court's failure to sua sponte instruct the jurors on the proper use of Minn. Stat. 634.20 relationship evidence was plain error, holding that the relevant law was unsettled at the time of appellate review, and therefore, Defendant failed to establish an error that was plain. At trial, the district court admitted section 634.20 evidence without sua sponge instructing the jurors on the proper use of that evidence. The court of appeals reversed due to the district court's failure to sua sponte instruct the jurors as such. The Supreme Court reversed, holding (1) for trials held after the release of this opinion, the rule that when a district court admits relationship evidence under Minn. Stat. 634.20 over a defendant's objection that the evidence does not satisfy section 634.20, the court must sua sponte instruct the jurors on the proper use of such evidence unless the defendant objects to the instruction by the court is hereby adopted; and (2) the district court's failure to give such an instruction was not an error that was plain. View "State v. Zinski" on Justia Law

The Supreme Court affirmed the judgment of the postconviction court summarily denying Appellant's claims for ineffective assistance of trial and appellate counsel without holding an evidentiary hearing, holding that Appellant's claims were barred by the relevant statute of limitations. Appellant was convicted of first-degree premeditated murder under an aiding-and-abetting theory of liability. The district court imposed a sentence of life without the possibility of release. Appellant later filed his postconviction petition requesting an evidentiary hearing on his claims for ineffective assistance of trial and appellate counsel and mentioning a motion for testing conducted under Minn. Stat. 590.01, subd. 1a. The postconviction court concluded that Appellant's claims were barred by the two-year statute of limitations, Minn. Stat. 590.01, subd. 4. The Supreme Court affirmed, holding (1) Appellant's claims were barred by the two-year statute of limitations; and (2) Appellant's reference to testing did not satisfy the requirements of subdivision 1a. View "Jackson v. State" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming Appellant's consecutive sentences, holding that consecutive sentences for Appellant's offenses were a departure for which the district court had to provide written reasons, and in the absence of those written reasons, Appellant's consecutive sentences were unauthorized by law. Appellant filed a motion to correct his consecutive sentences under Minn. R. Crim. P. 27.03, subd. 9. The district court construed the motion as a petition for postconviction relief, which it denied as untimely. The court of appeals reversed the determination that Appellant's motion must be construed as a postconviction petition but affirmed the consecutive sentences. The Supreme Court reversed. On remand, the district court modified Appellant's sentences to run concurrently. The court of appeals affirmed in part and reversed in part. The Supreme Court held (1) Minn. R. Crim. P. 29.04, subd. 6 does not allow the State to argue, without seeking review, that the court of appeals erroneously reversed the district court's determination that construed Appellant's motion as a postconviction petition; and (2) Appellant's consecutive sentences were unauthorized by law because they were an upward departure from the presumptive sentence under the applicable version of the guidelines and the district court failed to give any reason justifying the departure. View "Bilbro v. State" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the district court's grant of judgment on the pleadings to the State on Appellant's claims alleging false imprisonment and negligence, holding that the conditional release imposed under Minn. Stat. 169A.276, subd. 1(d), unambiguously begins when a Challenge Incarceration Program participant enters phase II of the program and begins living in the community. Appellant, a participant in the Challenge Incarceration Program administered by the Department of Corrections, brought this action arguing that the State failed correctly to calculate his conditional-release term and revoked his conditional release improperly after it had already ended. Specifically, Appellant argued that he was "released from prison" within the meaning of section 169A.276, subd. 1(d) when he entered phase II of that program. The district court granted the State's motion for judgment on the pleadings. The court of appeals affirmed. The Supreme Court reversed, holding that the conditional-release term imposed by section 169A.276, subd. 1(d), begins when a participant in the Challenge Incarceration Program begins living in the community. View "Heilman v. Courtney" on Justia Law

The Supreme Court affirmed the decision of the post conviction court denying Appellant's motion to correct his sentence, holding that because Minn. Stat. 609.185 does not require a sentence of life imprisonment with the possibility of release, Appellant's sentence under Minn. Stat. 609.106(2)(1), which requires life in prison without the possibility of release, was authorized by law. Appellant was convicted of first-degree murder of a peace officer engaged in official duties and sentenced to life imprisonment without the possibility of release under section 609.106(2)(1). Appellant later moved to correct this sentence, asking that he be resentenced to life with the possibility of release rather than life without the possibility of release. The postconviction court denied the motion. The Supreme Court affirmed, holding that release is not possible when a sentence is imposed under section 609.106(2)(1) for a conviction under section 609.185(a)(4). View "Evans v. State" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming Defendant’s first-degree burglary conviction, holding that the victim must be physically present during the burglary for a conviction under Minn. Stat. 609.582(1)(b). Section 609.582(1)(b) elevates burglary to a first-degree offense if “the burglar possesses, when entering or at any time while in the building,….any article used or fashioned in a manner to lead the victim to reasonably believe it to be a dangerous weapon.” On appeal, Defendant argued that because the victim was not physically present during the burglary, the evidence was not sufficient to support his conviction. The court of appeals affirmed. The Supreme Court reversed, holding that section 609.582(1)(b) requires the victim to be physically present during the burglary. View "State v. Rogers" on Justia Law

In this first-degree murder case the Supreme Court affirmed the judgment of the district court summarily denying Appellant’s second and third petitions for postconviction relief, holding that Appellant was conclusively entitled to no relief. In his petitions, Appellant alleged, among other things, that two of the State’s witnesses recanted, that he was denied his right to confront the witnesses against him, and that he was denied his right to self-representation. The postconviction court denied the petitions without a hearing. The Supreme Court affirmed, holding that the district court did not abuse its discretion in summarily denying postconviction relief because five of Appellant’s claims were filed after the statute of limitations expired and the sixth was legally insufficient to entitle Appellant to a new trial. View "Reed v. State" on Justia 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