Justia Minnesota Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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The Supreme Court reversed Defendant's conviction of depraved-mind murder and remanded this case to the district court for Defendant to be sentenced on a second-degree manslaughter conviction, holding that Defendant could not be convicted of depraved-mind murder.Justine Ruszczyk called the police out of concern for a woman she heard screaming, but when Ruszczyk approached the police vehicle that came in response to her call, Defendant fired his service weapon at her from the passenger seat. A jury acquitted Defendant of second-degree intentional murder but found him guilty of third-degree depraved-mind murder and second-degree manslaughter. At issue was whether, in addition to second-degree manslaughter, Defendant could also be convicted of depraved-mind murder. The Supreme Court held that he could not and reversed his conviction. View "State v. Noor" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the trial court convicting Defendant of first-degree criminal sexual conduct, holding that the modified plain error doctrine was not satisfied in this case.On appeal, Defendant argued that a statement made by the prosecutor during his jury trial required reversal of his conviction and a new trial. At issue was the prosecutor's statement to the jury during closing argument that a unanimous verdict on one element of the offense - specifically, whether Defendant acted with force or with coercion to accomplish the act of sexual penetration - was not required. The court of appeals affirmed, holding (1) the phrase "force or coercion in Minn. Stat. 609.342(a)(e)(i) sets forth alternative means for completing the sexual penetration element of the offense; and (2) therefore, a unanimous jury verdict on whether Defendant used force or coercion was not necessary. The Supreme Court affirmed, holding that no relief was warranted in this case. View "State v. Epps" on Justia Law

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The Supreme Court affirmed the judgment of the court of appeals affirmed Defendant's conviction but remanding the case to the district court for Defendant to be resentenced in accordance with modified guidelines, holding that the court of appeals did not err.Defendant was convicted and sentenced for criminal sexual conduct. At issue on appeal was whether a Minnesota Sentencing Guideline and associated commentary adopted by the Minnesota Sentencing Guidelines Commission but not ratified by the Legislature could abrogate the common law amelioration doctrine, which applies to a statute that mitigates the punishment for "acts committed before its effective date, as long as no final judgment has been reached." The court of appeals held (1) unratified statements by the Minnesota Sentencing Guidelines Commission could not abrogate the amelioration doctrine because they did not constitute a "statement by the Legislature"; and (2) Defendant was entitled to the benefit of a change in the Sentencing Guidelines adopted by the Commission in 2019, which resulted in a reduction of Defendant's criminal history score. The Supreme Court affirmed, holding that Defendant was entitled to resentencing under the amelioration doctrine. View "State v. Robinette" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the decision of the court of appeals reversing the decision of the district court granting Defendant's motion to suppress his statements to his probation officer and a polygraph administrator about his criminal conduct, holding that suppression of the statements was not required.Specifically, the Supreme Court held (1) Defendant made the statements at issue without invoking his constitutional privilege against self-incrimination, and the penalty exception to the general rule that a person cannot assert the privilege against self-incrimination without first invoking the privilege did not apply; (2) the portion of Minn. Stat. 634.03 requiring exclusion of confessions "made under the influence of fear produced by threats" excludes confessions made under circumstances where the inducement to speak was such that there was a fair risk that the confession was false; and (3) exclusion of Defendant's statements was not required in this case. View "State v. McCoy" on Justia Law

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The Supreme Court reversed the decision of the court of appeals determining that the district court judge presiding in the prosecution of Defendant was not disqualified or prohibited from presiding over Defendant's case, holding that Minn. R. Crim. P. 26.03, subd. 14(3) was violated when the judge continued to preside over Defendant's case.Defendant was charged with violating a domestic abuse no contact order. During trial, Defendant filed a motion to remove the judge for bias, arguing that the judge had claimed knowledge of a disputed fact and had contacted a potential witness regarding the disputed fact. Defendant's motion was denied, and he was convicted. The court of appeals affirmed. The Supreme Court reversed, holding (1) the judge's conduct during a pretrial proceeding reasonably caused the judge's impartiality to be questioned; (2) subdivision 14(3) was therefore violated when the judge continued to preside over Defendant's case; and (3) reversal of Defendant's conviction and a remand for a new hearing were required to pressure the public's confidence in the judicial system. View "State v. Malone" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed Defendant's conviction of first-degree premeditated murder and the decision of the district court denying Defendant's petition for postconviction relief, holding that there was no error.Specifically, the Supreme Court held (1) the evidence presented at trial was sufficient to support the jury's guilty verdict; (2) the State did not commit prosecutorial misconduct; (3) Defendant's trial counsel did not provide ineffective assistance; and (4) Defendant was not entitled to an evidentiary hearing to consider the opinions of two experts to determine whether a new trial was warranted. View "State v. Allwine" on Justia Law

Posted in: Criminal Law
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The Supreme Court reversed the decision of the court of appeals reversing the decision of the Commitment Appeal Panel (CAP) granting Appellant's petition for provisional discharge, holding that the record evidence reasonably supported the CAP's decision that the Commissioner for the Department of Human Services failed to prove by clear and convincing evidence that the provisional discharge was not appropriate for Appellant under Minn. Stat. 253D.30.Appellant was adjudicated delinquent of multiple sexual offenses against minors and was later convicted of first-degree criminal sexual conduct against a minor. Appellant was indeterminately committed to the Minnesota Sex Offender Program (MSOP) as a sexually dangerous person and was later transferred to MSOP's Community Preparation Services. Appellant later petitioned for a provisional discharge. The Special Review Board (SRB) recommended that Appellant's request for a provisional discharge be granted and the CAP granted the petition. The court of appeals reversed. The Supreme Court reversed, holding that the record as a whole reasonably supported the CAP's findings and that the CAP did not clearly err by granting Appellant's petition for provisional discharge. View "In re Civil Commitment of Kenney" on Justia Law

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The Supreme Court affirmed the judgment of the district court overruling Appellant's objection to the State's peremptory strike of a prospective juror, holding that Appellant did not meet his burden of proving that the State's race-neutral reason for the strike was a pretext for racial discrimination.Appellant was convicted of first- and second-degree criminal sexual conduct. On appeal, Defendant challenged the State's peremptory strike of the only nonwhite person from the jury venire. The court of appeals affirmed, holding that the prosecutor's explanations for striking the venire-person were race-neutral reasons for the peremptory strike. The Supreme Court affirmed, holding that the district court did not err in denying Appellant's Batson challenge to the State's peremptory strike of the juror. View "State v. Lufkins" on Justia Law

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The Supreme Court reversed the decision of the court of appeals reversing the orders of the district courts in four cases summarily denying postconviction petitions as untimely, holding that the petitions in this case were untimely.At issue was when the two-year time limit prescribed in Minn. Stat. 590.01, subd. 4(c) begins to run for postconviction petitions asserting a claim for relief based on a new, retroactive interpretation of the law. The Supreme Court held (1) the two-year time limit in subdivision 4(c) begins to run from the date the United States Supreme Court or a Minnesota appellate court announces an interpretation of law that forms the basis for a claim that the interpretation is a new rule of law that applies retroactively to the petitioner's postconviction petition; (2) application of the two-year time limit to bar Petitioners' postconviction petitions neither implicated separation of powers concerns nor violated constitutional due process protections; and (3) the postconviction petitions in this case were untimely. View "Aili v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed Defendant's convictions of two counts of first-degree premeditated murder for the deaths of an adult and an infant, holding that the district court erred in failing to suppress Defendant's statement to the police, the error was harmless beyond a reasonable doubt.Specifically, the Supreme Court held (1) Defendant's statement to police should have been suppressed because Defendant unambiguously invoked his constitutional right to remain silent during the police interrogation, but the failure to do so by the district court was harmless beyond a reasonable doubt; (2) the evidence was sufficient to prove that Defendant had an intent to kill when he fired the gunshot that killed the infant; and (3) the district court did not abuse its discretion by imposing consecutive sentences. View "State v. McInnis" on Justia Law