Articles Posted in Criminal Law

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The Supreme Court affirmed Defendant’s conviction for first-degree premeditated murder, holding that there was no abuse of discretion. On appeal, Defendant argued that the district court abused its discretion when it (1) declined to excuse a juror who, after the trial began, realized that she knew a witness and had been exposed to news coverage of the shooting; and (2) improperly excluded reverse-Spreigl alternative-perpetrator evidence. The Supreme Court disagreed, holding (1) the district court did not abuse its discretion in declining to remove the juror at issue from the jury; and (2) the district court did not abuse its discretion by excluding the reverse-Spreigl evidence. View "State v. Curtis" on Justia Law

Posted in: Criminal Law

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Appellant Emile Rey pleaded guilty to one count of identity theft involving eight or more direct victims. The district court ordered Rey to pay the mandatory-minimum restitution of $1,000 to each of his 66 direct victims, totaling $66,000. Rey appealed, asserting that the mandatory-minimum restitution he was ordered to pay violated his procedural and substantive due process rights and was an unconstitutional fine. The court of appeals affirmed. Rey asked the Minnesota Supreme Court to declare the statute unconstitutional, vacate the restitution order, and remand the matter for a restitution hearing or a Blakely trial. The Court declined, and affirmed the restitution order. View "Minnesota v. Rey" on Justia Law

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The Supreme Court reversed Defendant’s convictions of first-degree premeditated murder and second-degree intentional murder in connection with the stabbing death of Defendant’s girlfriend, holding that Defendant was entitled to a new trial because his defense counsel provided ineffective assistance by conceding the only disputed elements of the charged offenses without Defendant’s consent. Specifically, the court held (1) defense counsel conceded Defendant’s guilt to first-degree premeditated and second-degree intentional murder; and (2) Defendant was entitled to a new trial because he did not acquiesce in that concession. View "State v. Luby" on Justia Law

Posted in: Criminal Law

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Under the totality of the circumstances of this case, the police did not violate the Fourth Amendment when, during their execution of a warrant to search a home, they searched a purse that belonged to a guest at the home. Defendant was charged with third-degree controlled-substance crime for possessing methamphetamine. Defendant moved to suppress the methamphetamine found in her pursue, arguing that the search violated the Fourth Amendment because the search of her purse was beyond the scope of the search warrant. The district court denied the motion. The court of appeals affirmed. The Supreme Court affirmed, holding that, taken together, the facts showed that the search of Defendant’s purse was reasonable, and therefore, the search did not violate her Fourth Amendment rights. View "State v. Molnaux" on Justia Law

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The postconviction court did not abuse its discretion in when it denied Appellant’s second petition for postconviction relief without holding an evidentiary hearing. Appellant was found guilty of two counts of first-degree murder and sentenced to consecutive terms of life imprisonment without the possibility of release. The Supreme Court affirmed the convictions on direct appeal. In his first petition for postconviction relief, Appellant raised claims of ineffective assistance of trial and appellate counsel. The Supreme Court affirmed the postconviction court’s summary denial of the first petition. After hiring a private investigator to look into his case, Appellant filed a second postconviction petition. The Supreme Court affirmed the postconviction court’s summary denial of the petition, holding that even if Appellant proved the facts alleged in the petition at an evidentiary hearing, the petition, files, and records of the proceedings conclusively showed that Appellant was not entitled to relief. View "Zornes v. State" on Justia Law

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The chemical 1,1-difluoroethane (DFE) is not a hazardous substance under Minn. Stat. 169A.03(9) because it is not listed as a hazardous substance in Minn. R. ch. 5206. Appellant was arrested three times on suspicion of driving while impaired (DWI). An analysis of her blood showed the presence of DFE. Appellant was convicted of three counts of third-degree DWI for operating a motor vehicle while under the influence of a hazardous substance. The court of appeals affirmed. The Supreme Court reversed, holding that DFE is not a hazardous substance under the definition provided in section 169A.03(9). View "State v. Carson" on Justia Law

Posted in: Criminal Law

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The Supreme Court affirmed the court of appeals’ decision to uphold Defendant’s conviction for second-degree intentional murder but reversed the court’s reversal of Defendant’s sentence of 480 months in prison. The court of appeals concluded that the district court abused its discretion when it imposed the sentence, which reflected an upward durational departure from the presumptive range for 312 to 439 months, and remanded for resentencing. The Supreme Court held (1) the court of appeals properly affirmed Defendant’s conviction; and (2) the district court did not abuse its discretion when it concluded that there was a sufficient basis to enhance Defendant’s sentence from the presumptive guidelines range. View "State v. Parker" on Justia Law

Posted in: Criminal Law

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Plaintiff may file a petition for an order declaring her eligible for compensation under Minnesota’s Imprisonment and Exoneration Remedies Act, Minn. Stat. 590.11, 611.362-.368. Several years after the Supreme Court reversed Plaintiff’s conviction for second-degree manslaughter Plaintiff filed a petition seeking remuneration as an “exonerated” individual under section 590.11. The district court denied the petition, concluding (1) Petitioner was not “exonerated” under the statute because the prosecutor never dismissed the second-degree-manslaughter charge, and (2) the prosecutorial-dismissal requirement does not violate equal protection. The court of appeals, however, ruled that the prosecutorial-dismissal requirement violates equal protection and severed the requirement from the remainder of the provision rather than invalidating the entirety of section 590.11(1)(1)(i). The Supreme Court reversed, holding (1) Plaintiff was not “exonerated” under the statute when the Supreme Court reversed her conviction; (2) a statute cannot constitutionally require a prosecutor to dismiss charges that have already been reversed by an appellate court; and (3) the remedy for the as-applied equal-protection violation is to sever section 590.11(1)(1)(i) from the remainder of the statute. View "Back v. State" on Justia Law

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At issue was whether State v. Her, 862 N.W.2d 692 (Minn. 2015), applies retroactively to sentences that were imposed and became final before Her was decided. In Her, the Supreme Court ruled that the fact that a defendant was a risk-level-III offender at the time of the offense of failing to register as a predatory offender must be admitted by the defendant or found by a jury beyond a reasonable doubt before a court may impose a ten-year period of conditional release as part of the defendant’s sentence. The district court in this case granted Respondent’s motion to correct his sentence, concluding that Respondent’s ten-year conditional-release term was illegal because Her applied to the sentence. The Supreme Court reversed, holding that Her announced a new rule of constitutional criminal procedure that does not apply to the collateral review of Respondent’s sentence. View "State v. Meger" on Justia Law

Posted in: Criminal Law

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The part of Minnesota’s disorderly-conduct statute that prohibits “disturb[ing]” assemblies or meetings, Minn. Stat. 609.72(1)(2), violates the First Amendment. Defendant was convicted of disorderly conduct under section 609.72(1)(2) after a jury trial. On appeal, Defendant argued that the statute violates the First Amendment because it is unconstitutionally overbroad, unconstitutionally vague, and unconstitutional as applied. The court of appeals affirmed, concluding that the constitute was constitutional and was not subject to standard overbreadth analysis. The Supreme Court reversed, holding that the statute suffers from substantial overbreadth and that there is no reasonable narrowing construction of the statute. View "State v. Hensel" on Justia Law