Articles Posted in Criminal Law

Defendant was charged with two counts of second-degree intentional murder. Defendant filed a petition to plead guilty to both counts, but the petition was denied based on the State’s notice, right before the guilty-plea hearing, of its intent to seek a grand-jury indictment on first-degree murder charges. Thereafter, a grand jury returned an indictment charging Defendant with six counts of first-degree murder. The State dismissed the second-degree murder charges. Defendant pleaded guilty to one count of first-degree premeditated murder and one count of first-degree murder while committing a burglary. Defendant filed a petition for postconviction relief requesting that he be allowed to withdraw his guilty plea and instead plead guilty to the original second-degree murder charges. 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 denied Defendant’s petition for postconviction relief without holding an evidentiary hearing because Defendant failed to establish that withdrawal was necessary to correct a manifest injustice. View "Dikken v. State" on Justia Law

Defendant pleaded guilty to terroristic threats. As part of the factual basis for his plea, Defendant admitted that he posted five threatening tweets directed at law enforcement officers. Defendant filed a motion for a downward durational sentencing departure, which was warranted by his remorse, his intoxication, and the less serious nature of social media threats. The district court granted Defendant’s request. The Supreme Court vacated Defendant’s sentence and remanded to the district court for further proceedings, holding (1) Defendant’s “mental state” was not a proper reason to impose a downward durational sentencing departure; (2) the record did not reflect any offense-related remote that would provide an alternative ground to support the downward durational sentencing departure; and (3) the circumstances surrounding Defendant’s use of a social media platform to publish his threats did not mitigate his culpability. View "State v. Rund" on Justia Law

Defendant was found guilty of possession of a firearm by an ineligible person. The court of appeals reversed, concluding that the evidence was insufficient to support the conviction. The State petitioned for review, arguing that the court of appeals erred in its application of law and asking the Supreme Court to abandon the separate standard of review for convictions based on circumstantial evidence. The Supreme Court affirmed, holding (1) the court of appeals correctly applied the law and properly found that the State presented insufficient evidence to support Defendant’s conviction; and (2) the State has not established a compelling reason for the court to overrule an approximately century-old rule governing the review of convictions based on circumstantial evidence. View "State v. Harris" on Justia Law

Appellant was convicted of first-degree murder committed for the benefit of a gang. The Supreme Court affirmed. The day before the postconviction statute of limitations expired, Appellant filed his second petition for postconviction relief and, over the next six months, filed various addenda and attachments to his second petition. Appellant also filed a third petition raising additional claims and filed a motion requesting re-testing of certain trial evidence. Without holding an evidentiary hearing, the postconviction court denied both petitions and Appellant’s other requests, determining that his claims were untimely filed or procedurally barred, or failed on the merits. The Supreme Court affirmed, holding that each of the claims Appellant raised in his second and third petitions for postconviction relief, as well as the claims raised in the addenda to the second petition, failed. View "Brown v. State" on Justia Law

Appellant, a juvenile offender, challenged the district court’s imposition of three consecutive sentences of life imprisonment with the possibility of release after thirty years on each sentence for his three murder convictions. Appellant argued, among other things, that the rule announced in Miller v. Alabama and clarified in Montgomery v. Louisiana should apply to his case because his consecutive sentences were, in the aggregate, the functional equivalent of life imprisonment without the possibility of release. The Supreme Court affirmed, holding (1) this court declines to extend the Miller/Montgomery to include Appellant or other similarly situated offenders because the United States Supreme Court has not squarely addressed the issue of whether consecutive sentences should be viewed separately when conducting a proportionality analysis; and (2) Appellant’s three consecutive sentences do no unfairly exaggerate the criminality of his conduct. View "State v. Ali" on Justia Law

The Supreme Court affirmed Defendant’s conviction for first-degree felony murder rendered after a jury trial. The district court sentenced Defendant to life imprisonment with the possibility of release after thirty years. Specifically, the Court held (1) the State presented sufficient evidence to prove beyond a reasonable doubt that the killing of the victim occurred while Defendant was attempting to commit an aggravated robbery; and (2) the district court did not commit plain error by failing to include language requiring a causal relationship between the killing and the attempted robbery in the jury instruction on first-degree felony murder. View "State v. Webster" on Justia Law

In 2015, Appellant was charged with two counts of first-degree driving while impaired (DWI). Appellant contested the use of his 1998 conviction for criminal vehicular operation resulting in substantial bodily harm to enhance his 2015 DWI charge to a first-degree offense. The district court found sufficient probable cause for enhancement. Thereafter, Appellant pleaded guilty to one count of first-degree driving while impaired. Appellant appealed, arguing that he was entitled to withdraw his plea because his 1998 conviction was not included in the list of predicate felonies in Minn. Stat. 169A.24 that enhance a DWI charge to a first-degree DWI. The court of appeals affirmed. The Supreme Court affirmed, holding (1) a criminal vehicular operation conviction from a year not specifically listed in the current version of the first-degree DWI statute can be used to enhance a DWI charge to a first-degree offense; and (2) accordingly, Appellant’s plea was established with an accurate factual basis. View "State v. Boecker" on Justia Law

After a bench trial, Appellant was convicted of three counts of first-degree premeditated murder. The Supreme Court affirmed on direct appeal. Appellant then filed a pro se petition for postconviction relief, arguing that he was entitled to a new trial based on newly discovered evidence in the form of affidavits signed by five alibi witnesses. Appellant also claimed ineffective assistance of trial counsel and appellate counsel. The postconviction court summarily denied Appellant’s motion. The Supreme Court affirmed, holding that the postconviction court did not abuse its discretion by summarily denying Appellant’s request for a new trial based on newly discovered evidence and based on Appellant’s claim that both his trial counsel and appellate counsel provided ineffective assistance. View "State v. Mosley" on Justia Law

A grand jury indicted Appellant for first-degree premeditated murder. After a jury trial, Appellant was found guilty as charged. The district court sentenced Appellant to life imprisonment without the possibility of release. On appeal, Appellant argued that the district court committed reversible error in its pretrial rulings, evidentiary rulings, and instructions to the jury. The Supreme Court affirmed, holding that the district court (1) did not err by denying Appellant’s motion to quash the first-degree murder indictment as untimely; (2) did not abuse its discretion by denying Appellant’s pretrial motion to disclose the entire grand jury transcript; (3) did not err when it excluded evidence of an alternative perpetrator’s prior bad acts; (4) did not commit reversible error in its evidentiary rulings challenged on appeal; and (5) did not commit prejudicial error when it overruled Appellant’s objection to a proposed jury instruction on the law on accomplice liability. View "State v. Guzman" on Justia Law

Defendant was charged with gross misdemeanor second-degree driving while impaired. The matter proceeded to trial. After the State rested, Defendant made a motion for judgment of acquittal, arguing that there was insufficient evidence to convict him of the offense. Thereafter, the State asked to reopen its case-in-chief. The district court granted the State’s motion to reopen and then denied Defendant’s motion for judgment of acquittal. The jury found Defendant guilty as charged. The court of appeals affirmed, concluding that the district court did not err when it granted the State’s motion to reopen its case-in-chief before considering Defendant’s motion for judgment of acquittal. The Supreme Court affirmed, holding that, under the circumstances of this case, the district court did not abuse its discretion when it permitted the State to reopen its case-in-chief in response to Defendant’s motion for judgment of acquittal. View "State v. Thomas" on Justia Law