Justia Minnesota Supreme Court Opinion Summaries

After a fatal shooting in a shared Minneapolis apartment, the defendant was charged with first-degree murder while committing domestic abuse with a past pattern of domestic abuse, as well as being a prohibited person in possession of a firearm. The defendant and the victim had been in a relationship and lived together; on the day of the incident, the victim had communicated to others her intention to end their relationship. Later that day, following an argument, the defendant called 911 twice to report a shooting, providing inconsistent information about his location. When police arrived at the apartment, they found the victim dead from a gunshot wound. At trial, the State presented evidence of the defendant’s prior abusive conduct toward several other romantic partners, as well as expert testimony on the dynamics of domestic violence.The Hennepin County District Court conducted the jury trial. During jury selection, the State used a peremptory strike on the only remaining Black venire member, prompting a Batson challenge by the defense, which was denied. The district court allowed the State’s domestic violence expert testimony, over defense objections. The jury found the defendant guilty on all counts, and the district court entered convictions for first-degree murder and firearm possession, sentencing the defendant to life with the possibility of release after 30 years.On direct appeal to the Minnesota Supreme Court, the defendant raised four main issues: the denial of his Batson challenge, the admission of domestic violence expert testimony, alleged prosecutorial misconduct during closing arguments, and the absence of a specific-unanimity jury instruction regarding the domestic abuse element. The Minnesota Supreme Court held that the district court did not clearly err in denying the Batson challenge, did not abuse its discretion in admitting the expert testimony, and that the prosecutor’s statements did not constitute misconduct. Furthermore, it found that any instructional error did not affect the defendant’s substantial rights. The court affirmed the convictions. View "State of Minnesota vs. Brown" on Justia Law

A two-year-old child, T.B., was found dead in an apartment in Mankato, Minnesota, with evidence of physical and sexual assault. At the time of the incident, the child’s mother and her boyfriend, L.Y., left the apartment around midnight to purchase a car, leaving T.B., his sister, and Lee Wayne Young, Jr. (then 16 years old) at home. Later that day, T.B. was discovered unresponsive in his bed. Forensic evidence indicated T.B. died from multiple traumatic injuries, with signs of sexual assault and the presence of semen and DNA linked to Young. There was also a small amount of methamphetamine in T.B.’s system, but it was not the cause of death.After an investigation, Young was indicted on multiple counts including first-degree murder. At trial in the Blue Earth County District Court, Young presented an alternative perpetrator defense, alleging that L.Y. was responsible for T.B.’s death. The district court allowed this defense but excluded certain evidence Young sought to introduce, such as L.Y.’s internet search history, prior methamphetamine convictions, and a recorded statement to police. The court also excluded a portion of a squad car video and a learned treatise on confirmation bias. Young was convicted of first-degree murder and other charges by a jury.Young appealed directly to the Minnesota Supreme Court and also filed a postconviction petition, which the district court denied. The Minnesota Supreme Court consolidated both appeals. The court reviewed each of Young’s evidentiary challenges and the denial of postconviction relief. It held that the district court had not abused its discretion in any of its evidentiary rulings, found any possible error in excluding a learned treatise was harmless beyond a reasonable doubt, and concluded that the admission of undisclosed expert opinion testimony did not affect Young’s substantial rights. The cumulative effect of any errors did not deny Young a fair trial. The Minnesota Supreme Court affirmed the conviction and denial of postconviction relief. View "State of Minnesota vs. Young" on Justia Law

The case involves the conviction of an individual for first-degree premeditated murder following a drive-by shooting. The defendant, who was engaged in drug sales, accused the victim of stealing money and drugs from his apartment. Tensions escalated after the theft, with the defendant expressing a desire to have the victim killed. On the night of the murder, evidence—including surveillance footage, forensic analysis of bullet casings, and testimony—connected the defendant and an associate to the crime. The defendant fled the state but made incriminating statements before and after his arrest.A Hennepin County grand jury indicted the defendant on two counts of first-degree murder. The case proceeded to trial in Hennepin County District Court. During the proceedings, the court made three key rulings: it excluded hearsay evidence from a co-defendant’s cellmate under Rule 804 because the proponent had not shown the co-defendant was legally unavailable; it excluded evidence of Facebook messages between the victim and a third party, finding their probative value was outweighed by the risk of confusing the jury; and it denied the defendant’s motion for mistrial after a witness referenced an alleged sexual relationship between the defendant and a minor, instead issuing a curative instruction to the jury. The jury convicted the defendant on both counts, and the district court imposed a life sentence without the possibility of release.The Minnesota Supreme Court reviewed the case and affirmed the district court’s decisions. It held that the exclusion of the cellmate’s testimony was not an abuse of discretion because the defendant failed to establish the co-defendant’s unavailability. The exclusion of the Facebook evidence was affirmed as the risk of jury confusion outweighed any minimal probative value. The denial of the mistrial motion was also upheld, as there was no reasonable probability the outcome would have been different but for the contested testimony. View "State of Minnesota vs. Johnson" on Justia Law

A police officer attempted to stop a driver on a rural Minnesota highway shortly after midnight because he believed the van lacked a visible rear license plate or temporary registration. The driver, instead of stopping, turned on his hazard lights and continued driving for several miles with the officer in pursuit, ignoring repeated commands to stop. The pursuit ended only after additional officers joined and the driver stopped at a protest encampment. After his arrest, officers determined the van did have valid temporary registration, but the driver was charged with felony fleeing a peace officer in a motor vehicle.At trial in the District Court, the driver moved to suppress evidence of his flight, arguing that the initial traffic stop was unconstitutional and that the subsequent evidence of fleeing was “fruit of the poisonous tree.” The District Court denied the motion, finding the officer had an objective reason for the stop. A jury convicted the driver. On appeal, the Minnesota Court of Appeals held the traffic stop was unconstitutional but affirmed the conviction, concluding that the evidence of flight was admissible under existing law.The Minnesota Supreme Court reviewed whether, under the Minnesota Constitution, evidence of a defendant’s new crime—here, vehicular flight—committed in response to an unconstitutional seizure must be suppressed. The court held that courts should apply the four-factor attenuation test from State v. Warndahl to determine if such evidence is the fruit of the poisonous tree. Applying this test, the court found that the driver’s flight was an intervening act of free will that attenuated the connection to the unconstitutional stop, and thus, the exclusionary rule did not require suppression. The Supreme Court affirmed the decision of the Court of Appeals. View "State of Minnesota vs. Engel" on Justia Law

A police officer in Thief River Falls, Minnesota, attempted to stop Nicholas Engel’s van late at night because he did not see a rear license plate or visible temporary registration. Rather than pull over, Engel turned on his hazard lights and continued driving for several miles, despite the officer’s emergency lights, siren, and repeated verbal commands to stop. Engel eventually stopped only after additional officers arrived and boxed in his vehicle near a protest camp. He was arrested and charged with felony fleeing a peace officer in a motor vehicle.The Thief River Falls District Court denied Engel’s motion to suppress evidence of his vehicular flight, concluding the officer had an objective reason to initiate the stop. After a jury convicted Engel, the Minnesota Court of Appeals affirmed, though all panel members agreed the traffic stop was unconstitutional because the officer lacked reasonable, articulable suspicion for the stop. The majority held that suppression of evidence of Engel’s flight was not warranted, while the dissent argued that the flight was fruit of the unconstitutional seizure and should be suppressed.The Supreme Court of Minnesota reviewed the case to determine whether evidence of Engel’s vehicular flight, which constituted a new crime in response to an unconstitutional stop, must be suppressed under the exclusionary rule of the Minnesota Constitution. The court held that when a suspect commits a new crime after law enforcement commits a constitutional violation, courts must apply the four-factor attenuation test from State v. Warndahl to determine whether the evidence of the new crime is fruit of the poisonous tree. Applying this test, the court found Engel’s flight to be an intervening act not sufficiently connected to the unconstitutional stop to warrant suppression. The court affirmed the decision of the Court of Appeals. View "State of Minnesota vs. Engel" on Justia Law

In this case, the petitioner was convicted of second-degree unintentional felony murder, attempted second-degree murder, and first-degree aggravated robbery in connection with a 2013 incident in Minneapolis. The petitioner and his accomplice planned to commit robberies, ultimately attempting to rob several individuals. During the course of these events, the petitioner handed a pistol to his accomplice, who then used it to fatally shoot one of the victims. The petitioner subsequently pleaded guilty to the charges based on an aiding-and-abetting theory of liability.Following legislative changes in 2023 and 2024 that narrowed the scope of criminal liability for aiding and abetting second-degree felony murder, the petitioner sought to vacate his conviction under a new statutory procedure. He argued that he was not a “major participant” in the underlying felony and did not act with “extreme indifference to human life.” The Hennepin County District Court denied the petition without holding an evidentiary hearing, finding that the petitioner’s actions met both statutory criteria. The Minnesota Court of Appeals affirmed, applying a reasonable-probability standard that defined “reasonable probability” as “a probability sufficient to undermine confidence in the outcome of the case,” and concluded that the petitioner’s entitlement to relief was refuted by the record.The Supreme Court of Minnesota reviewed the case and clarified that the “reasonable probability” standard it previously articulated in State v. Zielinski, 32 N.W.3d 847 (Minn. 2026), applies to denials of petitions under this statutory scheme. The court held that the standard used by the court of appeals differed materially from the Zielinski standard. Consequently, the Supreme Court reversed the decision of the court of appeals and remanded the case for further proceedings using the correct legal standard. View "Grant vs. State of Minnesota" on Justia Law

Police officers investigated suspected fentanyl sales at an apartment in East Grand Forks, Minnesota, in 2022. After surveillance and a search warrant, they found Mohamed Abdulgani Ahmed at the apartment, arrested him, and discovered 775 fentanyl pills, cash, and Ahmed’s wallet in the bedroom closet. Forensic analysis confirmed the pills contained fentanyl weighing approximately 77.5 grams. Ahmed admitted to selling some fentanyl pills but denied knowledge of the large bag of pills. Text messages from Ahmed’s phone indicated involvement in fentanyl sales with his roommate, A.F., and others. Ahmed was charged with conspiracy to commit first-degree sale of controlled substances, first-degree sale, and second-degree possession of controlled substances.The District Court for Polk County entered convictions for all three counts after a jury trial. Ahmed appealed, arguing errors in the prosecution’s closing argument and other issues. The Minnesota Court of Appeals affirmed the convictions for conspiracy and sale but reversed and remanded for the district court to vacate the conviction for second-degree possession, as it was a lesser-included offense under Minnesota law.The Supreme Court of Minnesota reviewed whether the prosecutor’s statement—that the State need not prove Ahmed knew the conspiracy involved more than fifty grams of fentanyl—was plain error. The court held that, under Minnesota Statutes section 152.096 and its prior decision in State v. Kuhnau, the State must prove the defendant intended the commission of every element of the underlying offense, including the statutory weight threshold. The prosecutor’s misstatement was plain error affecting Ahmed’s substantial rights and was prejudicial. The Supreme Court reversed in part, vacated in part, and remanded for a new trial on all three challenged counts. View "State of Minnesota vs. Ahmed" on Justia Law

A 16-year-old girl disclosed to her high school advisor that her stepfather had sexually abused her, prompting a police investigation. The accused was charged with first-degree criminal sexual conduct, based on allegations that he committed multiple acts of sexual penetration against his minor stepdaughter over a period of about two years, beginning when she was around nine years old. The complainant described several acts of abuse, including cunnilingus and fellatio, occurring on different occasions and in different locations. Other family members and professionals testified about her disclosures and related observations. The defendant denied the allegations, and his defense emphasized inconsistencies in the complainant’s account and testimony from other relatives.After a jury trial, the Hennepin County District Court found the defendant guilty of both first- and second-degree criminal sexual conduct, entering judgment on the first-degree charge and sentencing him to 144 months in prison. The defendant appealed to the Minnesota Court of Appeals, arguing that the district court’s failure to provide a jury instruction requiring specific unanimity—that is, requiring jurors to agree on which specific act constituted the charged offense—constituted plain error. The Court of Appeals affirmed the conviction, relying in part on its prior decision in State v. Rucker, which held that a specific-unanimity instruction was not required under similar circumstances.The Supreme Court of Minnesota reviewed the case and held that, under its recent decision in State v. Keyes, when a single count is charged but the evidence involves multiple distinct acts, each capable of independently satisfying the statutory elements, a specific-unanimity jury instruction is required. The Court concluded that the district court’s failure to provide such an instruction was plain error that affected the defendant’s substantial rights. The Supreme Court of Minnesota reversed the first-degree conviction and remanded for a new trial on that charge. View "State of Minnesota vs. Yang" on Justia Law

In 2016, Tyrel Patterson and three accomplices participated in a burglary and robbery that resulted in the death of James Herron. Patterson was indicted on two counts of first-degree felony murder and ultimately pleaded guilty to one count under an aiding and abetting theory. He admitted to planning and executing the robbery, being armed, and robbing a resident, but maintained he was outside the house when Herron was fatally shot. He was sentenced to life in prison with the possibility of release after 30 years.Years later, Patterson petitioned the Scott County District Court to vacate his conviction under a new Minnesota law (the Act) that provides relief for certain felony murder convictions based on aiding and abetting, if the defendant did not cause the death or intentionally aid with the intent to cause death. The district court initially found a reasonable probability that Patterson could be entitled to relief, but ultimately denied his petition without holding an evidentiary hearing. The court relied on transcripts and findings from the trial of a co-defendant, concluding that Patterson caused Herron’s death.The Supreme Court of Minnesota reviewed the district court’s denial for abuse of discretion. It held that the district court erred by making credibility determinations without first holding an evidentiary hearing, as required by precedent and the Act’s procedural framework. The court reversed the district court’s decision and remanded the case for an evidentiary hearing to properly resolve disputed material facts and assess the credibility of the parties. The main holding is that a district court cannot make credibility determinations in proceedings under the Act without first conducting an evidentiary hearing. View "Patterson vs. State of Minnesota" on Justia Law

The case concerns a defendant who was charged with several offenses, including first-degree criminal sexual conduct, after an incident in which his former intimate partner, S.B., alleged that he committed two distinct acts of nonconsensual sexual penetration—one in a bedroom and one in a living room—during a violent episode. After the incident, S.B. reported the events to police, and the defendant was arrested at her home. Physical evidence supported S.B.’s account. The case proceeded to trial, where the primary dispute was whether the sexual assaults occurred as alleged.At trial in the Minnesota District Court, the defendant requested a specific-unanimity jury instruction, which would have required jurors to unanimously agree on which distinct act of sexual penetration satisfied the elements of the charged offense. The district court denied this request and instead gave a general-unanimity instruction. The jury found the defendant guilty on all counts, and he was sentenced to 360 months in prison. The defendant appealed to the Minnesota Court of Appeals, arguing that the failure to give a specific-unanimity instruction violated his right to a unanimous verdict. The Court of Appeals affirmed the convictions, concluding that the defendant had not properly preserved the issue and that the instruction was not required because the acts occurred as part of a single behavioral incident.The Supreme Court of Minnesota reviewed the case. The court held that when the State charges one count of criminal conduct but presents evidence of more than one distinct act, each of which on its own could prove the elements of the charged offense, a defendant is entitled to a specific-unanimity instruction. The district court abused its discretion in declining to give such an instruction. Further, the error was not harmless beyond a reasonable doubt because it was reasonably likely that jurors disagreed about which act constituted the offense. The Supreme Court of Minnesota reversed the convictions for first-degree criminal sexual conduct and remanded for a new trial. View "State of Minnesota vs. Keyes" on Justia Law