Justia Minnesota Supreme Court Opinion Summaries

Articles Posted in Criminal Law
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The Supreme Court affirmed the judgment of the district court denying Appellant's fourth postconviction petition alleging alleging a claim of newly-discovered evidence, holding that the district court did not abuse its discretion.Appellant was convicted of six counts of aiding and abetting first-degree murder for the benefit of a gang and sentenced to life in prison without the possibility of release. In his fourth postconviction petition, Defendant asserted a successive claim of newly discovered evidence based on three affidavits. The district court denied the petition, determining that the claims were time-barred. The Supreme Court affirmed, holding that the district court properly concluded that Appellant's fourth petition for postconviction relief was untimely. View "Caldwell v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the district court imposing a mandatory five-year conditional release term in connection with Defendant's conviction of fourth-degree assault of a secure treatment facility employee of the Minnesota Sex Offender Treatment Program (MSOP), holding that there was a rational basis for the sentencing disparity at issue in this case.After he was convicted, Defendant filed a petition for postconviction relief arguing that Minn. Stat. 609.2231, subd. 3a(e) required the district court to impose different sentences for the same conduct based on the defendant's civil commitment status, and therefore, his sentence violated his equal protection rights under the United States and Minnesota Constitutions. The district court denied postconviction relief, and the court of appeals affirmed. The Supreme Court affirmed, holding that the disparate sentence survived rational basis review. View "State v. Lee" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals affirming Defendant's convictions on two counts of first-degree burglary and two counts of second-degree assault, holding that there was no error.After the jury announced its verdicts in this case Defendant exercised his right to poll the jury. While the record showed that the jury was composed of twelve members, the transcript of the jury polling contained only eleven responses. On appeal, Defendant argued that the evidence was insufficient to prove that he was afforded his constitutional right to a unanimous, twelve-person jury. The court of appeals affirmed. The Supreme Court affirmed, holding (1) sufficient evidentiary support in the record established that Defendant was found guilty by a twelve-member jury; and (2) Defendant was not entitled to relief for any error in the jury polling because it was not a structural error, and Defendant did not satisfy the plain error doctrine. View "State v. Bey" on Justia Law

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The Supreme Court affirmed the judgment of the court of appeals affirming the district court's denial of Appellant's postconviction petition in which she argued that her restitution order should be reduced, holding that there was no error or abuse of discretion.Appellant was convicted of medical assistance fraud for submitting fraudulent Medicaid claims to the Minnesota Department of Human Services through a company she owned and operated. The district court convicted Appellant of racketeering and ordered her to pay a $2.64 million restitution award. In her postconviction motion Appellant argued that her restitution award should be reduced because DHS's economic loss had to account for the economic benefit it received from her offense. The district court denied relief. The Supreme Court affirmed, holding (1) Minn. Stat. 611A.045, subd. 1(a)(1) requires a district court to consider the value of any economic benefits a defendant conferred on a victim when calculating a restitution award; and (2) the district court did not abuse its discretion when it calculated DHS's economic loss. View "State v. Currin" on Justia Law

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The Supreme Court affirmed Defendant's conviction of first-degree murder and aggravated robbery, holding that Defendant was not entitled to relief on any of his claims of error.For the aggravated robbery, the district court imposed a ninety-six-month sentence, reflecting an upward durational departure, and for the first-degree murder the court imposed a consecutive sentence of life without the possibility of release. Defendant later filed a motion to correct his sentence, which the district court denied. The Supreme Court affirmed, holding (1) the district court correctly concluded that Defendant's claims under Minn. Stat. 609.135 failed on the merits and that the law of the case doctrine barred Defendant's challenges to his sentence; and (2) Defendant forfeited appellate review of his remaining claim. View "Smith v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the district court denying Appellant's motion to correct a sentence, holding that any alleged procedural error was harmless and that the district court was not required to hold a sentencing hearing.Appellant was serving a sentence of life in prison for first-degree murder when he filed a motion to correct his sentence under Minn. R. Crim. P. 27.03, subd. 9. In his motion, Appellant argued that his sentence was unlawful because he was not present during the pronouncement of his sentence, because the court failed to provide him an opportunity to personally address the court before it imposed a sentence, and because the court violated Minn. Stat. 609.035, subd. 1. The district court held (1) Appellant was correctly convicted of both first- and second-degree murder in violation of Minn. Stat. 609.04, and (2) Appellant's remaining claims were procedurally barred. The Supreme Court affirmed, holding that Appellant was not entitled to relief on his claims of error. View "Greer v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court reversed the judgment of the court of appeals affirming Defendant's conviction for interference with privacy after concluding that his guilty plea was accurate, holding that Defendant's guilty plea was not accurate because the plain language of Minn. Stat. 609.746, subd. 1(b) did not apply to his conduct.Defendant admitted to using his cell phone to record a women while she was naked in her bed without obtaining her consent and knowing that she likely would not have consented. At issue was whether Minn. Stat. 609.746, subd. 1(b), the statute Defendant pleaded guilty to violating, covered his conduct. The Supreme Court answered the question in the negative, holding that Defendant's conduct was not prohibited by the plain language of section 609.746, subd. 1(b)(2). View "State v. McReynolds" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the district court convicting Defendant of first-degree murder, second-degree intentional murder, and first-degree arson, holding that Defendant was not entitled to relief on his allegations of error.On appeal, Defendant argued that he was entitled to relief based on limitations that the district court placed on the presence of the public in the courtroom in response to the COVID-19 pandemic and that his motion for a hearing under Schwartz v. Minneapolis Suburban Bus Co., 104 N.W.2d 301 (Minn. 1960), and Minn. R. Crim. P. 26.03, subd. 20(6) should have been granted. The Supreme Court affirmed, holding (1) this Court will not exercise its limited discretion under the plain-error doctrine to grant relief based on objected-to limitations that the district court placed on the presence of the public in the trial courtroom due to the COVID-19 pandemic; and (2) the district court did not abuse its discretion by denying Defendant's request for a Schwartz hearing. View "Pulczinski v. State" on Justia Law

Posted in: Criminal Law
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The Supreme Court affirmed the judgment of the court of appeals affirming the judgment of the district court finding Defendant guilty of four counts of violence under Minn. Stat. 609.713, subd. 1, holding that section 609.713, subd. 1 does not violate the First Amendment.After he was charged, Defendant filed a motion to dismiss, claiming that the portion of section 609.713, subd. 1 that applies to threats of violence made "in a reckless disregard of the risk of causing such terror" was unconstitutionally overbroad. The district court denied the motion and found Defendant guilty. The court of appeals affirmed, concluding that even if the statute prohibited some protected speech, it was not facially overbroad under the First Amendment. The Supreme Court affirmed, holding (1) specific intent is not required to make a communication a true threat; (2) the statute punishes only reckless speech that is a true threat; and (3) because few situations of reckless but protected threats would be swept up in criminal prosecutions, the statute is not facially overbroad. View "State v. Mrozinski" on Justia Law

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The Supreme Court affirmed the judgment of the district court denying Defendant's fifth petition for postconviction relief, holding that the district court did not abuse its discretion in denying postconviction relief.After a jury trial, Defendant was found guilty of first-degree murder and sentenced to life in prison. At issue was Defendant's fifth postconviction petition for relief alleging a newly discovered evidence claim. The district court concluded that Defendant failed to satisfy the newly discovered evidence exception in Minn. Stat. 590.01, subd. 4(b)(2) and denied the petition. The Supreme Court affirmed, holding that the district court (1) properly excluded certain recordings of jail calls and an affidavit as inadmissible hearsay; and (2) did not abuse its discretion in denying Defendant's request for a new trial. View "Bobo v. State" on Justia Law

Posted in: Criminal Law