Justia Minnesota Supreme Court Opinion Summaries

In February 2021, Timothy Heller moved into his brother's house in Hennepin County, where his girlfriend, Lacy Krube, joined him. Shortly after, Lacy was asked to leave. The next day, Lacy was found severely beaten and later died from a stomach injury. Heller was arrested and charged with first-degree domestic abuse murder. Evidence included Heller's past domestic abuse against multiple victims and a witness testimony that Heller admitted to hitting Lacy.The Hennepin County District Court convicted Heller of first-degree domestic abuse murder. Heller appealed, arguing errors in jury instructions, admission of past abuse evidence, expert testimony on lethality factors, and exclusion of alternative-perpetrator evidence. The district court had allowed evidence of Heller's past abuse, including a 2000 conviction for abusing J.L., and expert testimony on lethality factors, but excluded certain evidence related to Heller's alternative-perpetrator defense.The Minnesota Supreme Court reviewed the case. It held that any error in the venue instruction was harmless beyond a reasonable doubt. The court found that evidence of singular acts of abuse against different victims constituted a past pattern of domestic abuse under Minnesota law. The court also ruled that the district court did not abuse its discretion in admitting evidence of Heller's past abuse, as it showed a consistent pattern of behavior. However, the court found that admitting expert testimony on lethality factors was an error, but it was harmless. The court upheld the exclusion of certain alternative-perpetrator evidence, finding no abuse of discretion.The Minnesota Supreme Court affirmed the district court's decision, concluding that the errors identified did not significantly impact the verdict. View "State vs. Heller" on Justia Law

Julian Valdez was convicted of second-degree unintentional felony murder for fatally shooting Pablo Gutierrez, who was allegedly attacking Valdez's stepbrother. The incident occurred after Gutierrez, who appeared agitated and unarmed, entered Valdez's garage and later got into a physical altercation with Valdez's stepbrother. Valdez retrieved a gun and, during the altercation, shot Gutierrez once, resulting in his death. Valdez claimed he acted in defense of his stepbrother, who was being choked by Gutierrez.The district court instructed the jury that Valdez had a duty to retreat before using force in defense of his stepbrother. Valdez was found guilty of second-degree unintentional felony murder. He appealed, arguing that the district court's instruction was erroneous. The Minnesota Court of Appeals agreed, concluding that the district court abused its discretion by instructing the jury that Valdez had a duty to retreat. The court of appeals reversed Valdez's conviction and remanded for a new trial, finding that the erroneous instruction was not harmless beyond a reasonable doubt.The Minnesota Supreme Court reviewed the case and affirmed the court of appeals' decision. The Supreme Court held that the district court abused its discretion by instructing the jury that Valdez had a duty to retreat before acting in defense of his stepbrother. The court clarified that, to justifiably use force in defense of another, a defendant must subjectively believe that the person in peril has no reasonable possibility of safe retreat, and that belief must be objectively reasonable based on the information available at the time. The court also concluded that the erroneous instruction was not harmless, as it could not be said beyond a reasonable doubt that the error had no significant impact on the verdict. Therefore, Valdez's conviction was reversed, and the case was remanded for a new trial. View "State vs. Valdez" on Justia Law

In the late evening of January 24, 2022, Brandon Moore was driving a car with expired registration tabs when he was pursued by police. After a brief chase, Moore was arrested. During the search, officers found over six grams of methamphetamine in Moore's pockets, $3,400 in cash in the car's center console, and a handgun along with more than 110 grams of methamphetamine in the locked glove compartment. The key to the glove compartment was in the ignition.Moore was charged with aggravated first-degree controlled substance crime (sale and possession) and ineligible possession of a firearm. The jury found Moore guilty on all counts. The district court entered convictions for ineligible possession of a firearm and aggravated first-degree controlled substance crime for sale, sentencing Moore to 98 months in prison. Moore appealed, arguing that the evidence was insufficient to prove the firearm was "within immediate reach" as required by the statute because it was in a locked glove compartment.The Minnesota Court of Appeals affirmed the conviction, interpreting "within immediate reach" to include both spatial and temporal proximity, meaning the firearm was accessible without delay and close at hand. Moore then petitioned the Minnesota Supreme Court, which reviewed whether the evidence was sufficient to prove the firearm was "within immediate reach."The Minnesota Supreme Court held that "within immediate reach" does not require instant accessibility. The court concluded that the evidence was sufficient to prove the firearm was within Moore's immediate reach because he was in the driver’s seat and the key to the glove compartment was in the ignition. Therefore, the court affirmed the decision of the court of appeals. View "State vs. Moore" on Justia Law

In 2015, the appellant sexually assaulted a 9-year-old girl, but the crime was not reported until 2021. In the interim, the appellant committed an unrelated second-degree assault in 2016, for which he was convicted in 2017. After the 2015 sexual assault was disclosed in 2021, the appellant was charged and convicted of second-degree criminal sexual conduct.The district court found the appellant guilty of two counts of second-degree criminal sexual conduct. During sentencing, the court applied a sentencing enhancement under Minnesota Statutes section 609.3455, subdivision 3a, classifying the appellant as an engrained offender due to his prior conviction for second-degree assault. This resulted in an upward durational departure of 250 months in prison with a lifetime conditional release term. The appellant appealed, arguing that the term "previously committed" in the statute should mean a predatory crime committed before the commission of the present offense, not before the sentencing determination.The Minnesota Court of Appeals affirmed the district court's decision, holding that the statute required only that the predatory crime be committed before the sentencing determination. The appellant then sought review from the Minnesota Supreme Court.The Minnesota Supreme Court affirmed the lower court's decision, holding that for enhanced sentencing under Minnesota Statutes section 609.3455, subdivision 3a, a predatory crime is considered "previously committed" if it is committed before the fact-finder's sentencing-related determination that the offender is a danger to public safety. The court concluded that the plain language of the statute supports this interpretation, and thus, the appellant's 2017 assault conviction qualified as a "previously committed" predatory crime for the purposes of sentencing enhancement. View "State vs. Balsley" on Justia Law

On August 10, 2021, Jeron Garding was arrested for first-degree narcotics charges after a drug-dog sniff of his parked car led to the discovery of approximately 410 grams of methamphetamine. Garding moved to suppress the evidence, arguing that law enforcement lacked reasonable, articulable suspicion to conduct the drug-dog sniff. The district court held a contested omnibus hearing where State Trooper Jacob Bredsten testified about his observations, including the suspicious behavior of Garding and his passenger, signs of the passenger’s recent drug use, and a plastic bag in the backseat that appeared to contain drugs.The district court denied Garding’s motion to suppress, finding that Trooper Bredsten had reasonable, articulable suspicion to conduct the drug-dog sniff based on the totality of the circumstances. Garding was subsequently convicted of first-degree possession of narcotics after a stipulated facts trial, preserving his right to appeal the suppression ruling. The Minnesota Court of Appeals reversed the district court’s decision, concluding that the trooper lacked reasonable, articulable suspicion to justify the drug-dog sniff.The Minnesota Supreme Court reviewed the case and reversed the Court of Appeals' decision. The Supreme Court held that, under the totality of the circumstances, Trooper Bredsten had reasonable, articulable suspicion to conduct the drug-dog sniff. The court emphasized that the combination of the passenger’s signs of recent drug use, the appearance of the plastic bag in the backseat, and Garding’s flight to the woods provided sufficient grounds for the suspicion. Therefore, the district court did not err in denying Garding’s motion to suppress the evidence obtained from the search. View "State v. Garding" on Justia Law

The appellant, Earley Romero Blevins, was charged with two counts of second-degree assault-fear with a dangerous weapon after brandishing a machete at a woman and two men on a light rail platform in downtown Minneapolis. Blevins claimed he acted in self-defense after one of the men threatened him with a knife. The incident was captured on surveillance video, which showed Blevins swinging the machete for about a minute, causing the woman and the two men to retreat.The district court found Blevins guilty, concluding that he had a reasonable opportunity to retreat but failed to do so, thus his actions were not justified under Minnesota's self-defense statute. The court sentenced him to a presumptive 39-month prison term. The Minnesota Court of Appeals affirmed the district court's decision, agreeing that the evidence supported the finding that Blevins had a reasonable opportunity to retreat.The Minnesota Supreme Court reviewed the case to address whether the judicially created duty to retreat when reasonably possible applies to a person claiming self-defense in committing the felony offense of second-degree assault-fear with a dangerous weapon. The court held that this duty does apply in such cases, specifically when the weapon is designed to cause death or great bodily harm. The court also concluded that the surveillance video evidence disproved Blevins's claim that he lacked a reasonable opportunity to retreat.The Minnesota Supreme Court affirmed the decision of the court of appeals, holding that Blevins had a duty to retreat when reasonably possible before brandishing the machete and that the evidence showed he had such an opportunity. View "State of Minnesota vs. Blevins" on Justia Law

The case involves the fatal shooting of Abdi Abdi on September 10, 2021, in Moorhead, Minnesota. The shooter exited a Chrysler 200, chased Abdi, and shot him multiple times, resulting in Abdi's death. At the time of the shooting, Ibrahim Abdiaziz Isaac, the appellant, was driving on Interstate 94, approximately 100 miles away. The State's theory was that Isaac knew about the shooter's plan to kill Abdi and aided by purchasing the Chrysler 200 for the shooter.A grand jury indicted Isaac for first-degree premeditated murder under an aiding-and-abetting theory. Isaac waived his right to a jury trial, opting for a court trial instead. The district court found Isaac guilty and sentenced him to life in prison without the possibility of release. The court based its decision on circumstantial evidence, including cell phone data, surveillance footage, and eyewitness testimony, which suggested that Isaac and the shooter traveled together to purchase the Chrysler 200 and that Isaac filled the car with gas before the shooter used it to commit the murder.The Minnesota Supreme Court reviewed the case. The court applied a two-step standard of review for circumstantial evidence, first identifying the circumstances proved and then determining whether these circumstances were consistent with guilt and inconsistent with any rational hypothesis other than guilt. The court concluded that the State presented insufficient evidence to prove beyond a reasonable doubt that Isaac knew about the shooter's plan to murder Abdi before the murder occurred. The court found that a rational hypothesis existed that Isaac only learned about the plan after the murder, as evidenced by his actions following a phone call from the shooter after the murder had taken place.The Minnesota Supreme Court reversed Isaac's conviction for first-degree premeditated murder under an aiding-and-abetting theory of criminal liability. View "State of Minnesota vs. Isaac" on Justia Law

Melissa Zielinski was convicted of first-degree intentional murder and second-degree intentional murder under aiding-and-abetting theories. The case arose from the robbery and fatal shooting of Karl Henderson. Zielinski and her brother, Nicholas, planned to rob Henderson, who was known to keep large sums of money in a safe. During the robbery, Nicholas shot Henderson. Evidence included DNA on the stolen safe, phone location data, and witness testimony.The district court denied Zielinski’s pretrial motion to suppress evidence obtained from her cell phone and her statements to police, finding the search warrants valid and the police questioning lawful. Zielinski was convicted by a jury and sentenced to life without parole for first-degree murder. Her postconviction petition, alleging ineffective assistance of counsel for not challenging the search warrants on particularity grounds, was summarily denied.The Minnesota Supreme Court reviewed the case. It held that any potential Fourth Amendment violation from police questioning was harmless beyond a reasonable doubt due to the overwhelming evidence of guilt. Similarly, any Sixth Amendment violation from limiting cross-examination of Nicholas was also deemed harmless. The court agreed that the district court erred in entering convictions for both first-degree and second-degree murder, as the latter is a lesser-included offense of the former. The court affirmed the first-degree murder conviction, reversed the second-degree murder conviction, and remanded to vacate the latter. The court also upheld the denial of Zielinski’s postconviction relief petition, finding no reasonable probability that the trial outcome would have been different even if the challenged evidence had been excluded. View "State of Minnesota vs. Zielinski" on Justia Law

In February 2019, Keegan Brouillette was found guilty by a jury of two counts of felony domestic assault. On June 24, 2019, the district court sentenced him to 15 months in prison but stayed the execution of the sentence for five years, placing him on supervised probation. Brouillette did not appeal his conviction or sentence. In August 2021, after violating probation, the district court revoked his probation and executed the previously imposed 15-month sentence. Brouillette served his sentence and, in July 2022, filed a petition for postconviction relief, alleging prosecutorial misconduct.The district court denied Brouillette’s petition as untimely, ruling that the August 2021 order executing the sentence was not a new sentence and did not restart the two-year deadline for filing a postconviction petition. The court of appeals affirmed this decision, agreeing that the August 2021 order merely executed the previously imposed sentence without modifying it.The Minnesota Supreme Court reviewed the case to determine whether the two-year limitations period for filing a postconviction petition under Minnesota Statutes section 590.01, subdivision 4(a), began with the original sentencing in June 2019 or the execution of the sentence in August 2021. The court held that the execution of a previously imposed sentence does not constitute a new sentence and, therefore, does not restart the two-year limitations period. The court affirmed the lower courts' decisions, concluding that Brouillette’s petition was untimely as it was filed more than two years after the original sentencing in June 2019. View "Brouillette vs. State of Minnesota" on Justia Law

The case involves Frank James Bigbear, who was charged with third-degree criminal sexual conduct for sexually assaulting a 14-year-old victim, I.M. The State of Minnesota presented multiple witnesses, including the victim, and introduced over 10 exhibits at trial. Among the evidence was a video recording of I.M.'s interview with an investigator and a social worker, which was admitted over Bigbear's hearsay objection. The jury found Bigbear guilty after a three-day trial.Bigbear appealed the conviction, arguing that the admission of the recorded interview was reversible error. The Minnesota Court of Appeals agreed that the video recording did not meet the requirements of Rules 801(d)(1)(B) and 807 of the Minnesota Rules of Evidence. However, the court concluded that the error was harmless, reasoning that the jury could have reached the same verdict based on other evidence presented.The Minnesota Supreme Court reviewed whether the Court of Appeals conducted an incorrect harmless-error analysis. The Supreme Court agreed that the lower court used an improper standard by focusing solely on whether other evidence was sufficient to support the verdict, rather than whether the erroneously admitted evidence substantially influenced the jury's decision. After applying the correct harmless-error standard, the Supreme Court concluded that the erroneous admission of the video was harmless. The court noted that the evidence against Bigbear was overwhelming, including consistent testimonies from the victim and eyewitnesses. Therefore, the Supreme Court affirmed the decision of the Court of Appeals to uphold Bigbear's conviction. View "State of Minnesota vs. Bigbear" on Justia Law