Justia Minnesota Supreme Court Opinion Summaries

In early 2021, Jason Turner Johnson was charged with first-degree burglary and fifth-degree assault in Minnesota. Later, an additional charge of second-degree burglary was added. Johnson pleaded guilty to the second-degree burglary charge, and the other charges were dismissed. He was sentenced to 28 months in prison, but the sentence was stayed, and he was placed on probation for five years. In August 2023, Johnson's probation officer reported multiple probation violations, including new criminal charges and failure to contact his probation officer. Johnson requested jail credit for time spent in custody in North Dakota, which the district court partially granted.The district court revoked Johnson's probation, executed his stayed sentence, and awarded him partial jail credit for time spent in custody in North Dakota. The State of Minnesota appealed the jail credit determination. Johnson moved to dismiss the appeal, arguing that the State had no right to appeal the jail credit determination. The Minnesota Court of Appeals denied Johnson's motion, holding that the State's right to appeal a jail credit determination arises by necessary implication from its right to appeal any sentence imposed or stayed by the district court in a felony case.The Minnesota Supreme Court reviewed the case to determine whether the State could appeal the district court's jail credit determination following a probation revocation. The court concluded that the State's right to appeal a jail credit determination arises by necessary implication from its express right to appeal a probation revocation decision under Minnesota Rule of Criminal Procedure 27.04, subdivision 3(4)(a). Therefore, the court affirmed the decision of the court of appeals, allowing the State's appeal to proceed. View "State of Minnesota vs. Johnson" on Justia Law

Ryan Charles Rooney was found guilty of first-degree domestic abuse murder after a jury trial and was sentenced to life in prison with the possibility of parole. Rooney appealed, arguing that the district court abused its discretion by precluding his alternative-perpetrator evidence and erred in denying his motion to suppress statements made to police officers. The case involves the murder of Rooney’s wife, Samantha Columbus-Boshey, whose body was found in a hotel room they had been staying in with her two young children.The district court precluded Rooney's alternative-perpetrator evidence, finding that he did not meet the foundational requirement to introduce such evidence. Additionally, the court denied Rooney's motion to suppress his statements to police officers, concluding that the statements were made voluntarily despite Rooney's head injury and hospitalization.The Minnesota Supreme Court reviewed the case and affirmed the district court's decisions. The court held that the district court did not abuse its discretion in precluding the alternative-perpetrator evidence, as Rooney failed to provide evidence with an inherent tendency to connect the third person, D.G., to the actual commission of the crime. The court also found that the district court correctly determined that Rooney's statements to police were voluntary, considering the totality of the circumstances, including his ability to comprehend and the nature of the interrogation.The Supreme Court concluded that the district court's rulings were based on a correct application of the law and were supported by the evidence. Therefore, the judgment of conviction was affirmed. View "State of Minnesota vs. Rooney" on Justia Law

In 1997, Milton K. Sanders was found guilty by a jury of one count of first-degree murder and two counts of attempted first-degree murder. The district court sentenced him to life in prison for the first-degree murder conviction and to consecutive 180-month prison sentences for the attempted first-degree murder convictions. Sanders's convictions and sentences were affirmed on appeal in 1999.In May 2024, Sanders filed a motion to correct his sentence, arguing that his consecutive sentences were unauthorized by law because they exaggerated the criminality of his conduct and were based on an incorrect criminal history score. The district court denied his motion, concluding that the sentences were authorized by law and that any error related to the criminal history score was harmless.The Minnesota Supreme Court reviewed the case. The court held that Sanders's argument regarding the exaggeration of his criminality was barred by the law of the case doctrine, as it had been previously addressed and denied in his direct appeal. Additionally, the court found that the consecutive sentences did not unfairly exaggerate the criminality of Sanders's conduct, as each offense involved a different victim, consistent with past sentences for similar offenses.Regarding the criminal history score, the court determined that any error in the district court's failure to pronounce Sanders's criminal history score at sentencing was harmless. The life sentence for first-degree murder was mandatory and unaffected by the criminal history score. The consecutive 180-month sentences for attempted first-degree murder were consistent with the presumptive sentence for a criminal history score of zero, as required by the sentencing guidelines.The Minnesota Supreme Court affirmed the district court's decision, concluding that the sentences were authorized by law and that any error related to the criminal history score was harmless. View "Sanders vs. State of Minnesota" on Justia Law

In 2011, Carlos Heard was convicted of third-degree depraved-mind murder and second-degree intentional murder for shooting and killing his brother and another person during a struggle over a gun. The district court sentenced him to 313 months for second-degree intentional murder and 180 months for third-degree depraved-mind murder. Heard appealed to the Minnesota Court of Appeals, challenging the district court's decision to allow impeachment evidence at his trial. The court of appeals affirmed his convictions, and the Minnesota Supreme Court denied review. Heard subsequently filed four postconviction petitions, all of which were denied.In 2023, Heard filed a fifth postconviction petition, arguing that the Minnesota Supreme Court's decisions in State v. Coleman and State v. Noor announced new substantive rules regarding the mental-state element of third-degree depraved-mind murder, which should apply retroactively to his case. The district court denied his petition, and the court of appeals affirmed, holding that Coleman and Noor did not announce new rules but rather clarified existing law.The Minnesota Supreme Court reviewed the case and concluded that Coleman and Noor did announce new rules of substantive law that apply retroactively. Coleman clarified that the mental-state element for third-degree depraved-mind murder requires a showing of reckless disregard for human life, while Noor held that this mental state cannot exist when the defendant's actions are directed at a particular person. The court also held that a postconviction petitioner is not required to independently satisfy the requirements of State v. Knaffla if the petitioner establishes that a new interpretation of state law is retroactively applicable in the first postconviction petition filed after the new interpretation is announced.The Minnesota Supreme Court reversed the court of appeals' decision and remanded the case to the district court to consider the effect of Coleman and Noor on Heard's third-degree depraved-mind murder conviction. View "Heard v. State" on Justia Law

A 15-year-old girl, S.W., left her home in Anoka County, Minnesota, without permission to stay with her mother’s cousin, A.G., in Wisconsin, where A.G. lived with the defendant, Paulson. After using methamphetamine together, Paulson assaulted A.G., took S.W. to his family’s property in Stacy, Minnesota, and kept her there for two days, during which he threatened her, provided her with drugs, and sexually assaulted her. S.W. was eventually recovered in Anoka County, where she reported the kidnapping and assaults to police.Paulson was initially charged in Anoka County District Court with first- and second-degree criminal sexual conduct. He moved to dismiss, arguing the offenses occurred in Isanti County, not Anoka County. The district court denied the motion, finding venue proper in Anoka County under Minnesota Statutes section 627.15, since S.W. was found there. The State later amended the complaint to add a kidnapping charge, to which Paulson entered an Alford plea. He did not challenge venue for the new charge. The district court accepted the plea and imposed sentence. On appeal, Paulson argued that his plea was invalid because the factual basis did not establish that venue was proper in Anoka County as required by Minnesota Statutes section 627.01. The Minnesota Court of Appeals rejected this argument, holding that venue is not an element of the offense.The Minnesota Supreme Court reviewed whether the statutory venue requirement is an element of the offense for purposes of the accuracy requirement of a guilty plea. The court held that the venue requirement in section 627.01 is not an element of the offense, and therefore, the factual basis for Paulson’s guilty plea was sufficient even though it did not establish venue. The decision of the court of appeals was affirmed. View "State of Minnesota vs. Paulson" on Justia Law

Samuel Alejondro Torrez was arrested for driving while impaired and driving after license cancellation. Law enforcement obtained a search warrant to test Torrez’s blood or urine, which he refused. Torrez was charged with first-degree test refusal and driving after license cancellation. Before trial, Torrez requested the district court to instruct the jury that the State must prove the arresting officer had probable cause to believe he was driving while impaired. The district court denied this request, and the jury found Torrez guilty on both counts.The Minnesota Court of Appeals affirmed Torrez’s conviction, concluding that the district court did not abuse its discretion by not including a probable cause element in the jury instructions. The court reasoned that the issuance of the search warrant already established probable cause.The Minnesota Supreme Court reviewed whether Minnesota Statutes section 169A.20, subdivision 2(2), requires the State to prove that the arresting officer had probable cause to believe the defendant was driving while impaired. The court held that the plain language of the statute does not require the State to prove probable cause for the refusal of a blood or urine test when a search warrant is involved. The court affirmed the decision of the court of appeals, concluding that the district court did not err in its jury instructions. View "State v. Torrez" on Justia Law

The State charged Larry Joe Foster with second-degree intentional murder for the death of Daniel Bradley. Foster claimed that another person, R.J., committed the murder. The district court determined that Foster met the requirements to present an alternative perpetrator defense and allowed him to introduce evidence supporting his claim. Foster intended to call R.J. as a witness, but R.J. invoked his right against self-incrimination before the trial. Foster requested that R.J. be required to invoke this right in front of the jury, but the district court denied the request, citing the lack of probative value and the cumulative nature of the evidence.The jury found Foster guilty of second-degree murder. Foster appealed, arguing that the district court violated his constitutional rights by not allowing him to call R.J. to the stand. The Minnesota Court of Appeals affirmed Foster’s conviction, concluding that he had no constitutional right to call R.J. solely to invoke his right against self-incrimination.The Minnesota Supreme Court reviewed the case and held that when a defendant has satisfied the required test to present an alternative perpetrator defense, the district court has discretion to allow the defendant to call the alternative perpetrator as a witness, even if it is known that the alternative perpetrator will invoke their right against self-incrimination. However, the district court must apply the ordinary rules of evidence in making this determination. The Supreme Court concluded that the district court did not abuse its discretion in denying Foster’s request, as the invocation of the right against self-incrimination by R.J. would have been needlessly cumulative. The decision of the court of appeals was affirmed on different grounds. View "State v. Foster" on Justia Law

In 2002, Fred Williamson was fatally shot while in a car in Minneapolis. B.H., a passenger in Williamson's car, initially claimed he did not see the shooter. Later, B.H. was indicted on unrelated federal drug charges and agreed to provide substantial assistance in Williamson's murder investigation in exchange for a potential sentence reduction. At trial, B.H. identified Leroy Roderick Paul as the shooter. Paul was convicted of first-degree murder during a drive-by shooting and sentenced to life in prison. His conviction was affirmed on direct appeal.Paul filed a petition for postconviction relief in 2023, claiming the State violated Brady v. Maryland and Giglio v. United States by not disclosing the specific terms of B.H.'s plea agreement. The district court denied the petition without an evidentiary hearing, finding no factual support for Paul's claim and determining the petition was untimely under the two-year statutory time bar.The Minnesota Supreme Court reviewed the case and affirmed the district court's decision. The court held that the evidence presented by Paul, even if accepted as true, did not support his claim that B.H. had negotiated a specific sentence. The court also found that Paul's petition was untimely and did not meet the exceptions for newly discovered evidence or interests of justice. The court concluded that the district court did not abuse its discretion in summarily denying the petition. View "Paul v. State" on Justia Law

Eloisa Rubi Plancarte was convicted of misdemeanor indecent exposure under Minnesota Statutes section 617.23, subdivision 1(1) for exposing her breasts in a gas station parking lot. Plancarte argued that her breasts are not "private parts" under the statute and that her exposure was not "lewd." She also claimed that prosecuting her for conduct that men are allowed to engage in violated her constitutional right to equal protection. The district court denied her motion to dismiss, and she was found guilty in a stipulated-evidence trial.Plancarte appealed her conviction, but the court of appeals affirmed it in a divided opinion. The majority concluded that the evidence was sufficient to support the conviction, while the dissent argued that the statute requires lewd conduct in addition to exposure, which was not proven in this case.The Minnesota Supreme Court reviewed the case and concluded that the term "lewdly" in the statute refers to conduct of a sexual nature. The court found that the State did not present sufficient evidence to prove that Plancarte's exposure was lewd, as there was no indication that her conduct was of a sexual nature. Consequently, the court reversed Plancarte's conviction. The court did not address whether female breasts are "private parts" under the statute or the equal protection claim, as the decision on the lewdness element resolved the case. View "State v. Plancarte" on Justia Law

Henry Lee Brown was involved in a fatal collision in 2021 while driving near his home in Minneapolis. After hitting and killing a pedestrian, Brown did not stop at the scene and drove home without notifying the police. He was charged with two counts of criminal vehicular homicide, including leaving the scene of a collision. Brown initially pled not guilty but later changed his plea to guilty for leaving the scene after causing the collision. He admitted to driving the vehicle and leaving the scene but claimed he was unconscious at the time of the collision due to a medical incident.The district court denied Brown's motion to withdraw his guilty plea and sentenced him to 58 months in prison. Brown appealed, arguing that the statute required the State to prove he was volitionally operating the vehicle at the time of the collision. The court of appeals affirmed the district court's decision, holding that the statute did not require volitional operation at the time of the collision.The Minnesota Supreme Court reviewed the case to determine whether the criminal vehicular homicide statute required proof of volitional operation at the time of the collision. The court concluded that the statute does not require an act of operation at the time of the collision. Instead, an act of operating a motor vehicle that takes place before a collision can satisfy the statute's requirements. The court affirmed the decision of the court of appeals on other grounds, holding that Brown's factual basis for his guilty plea was adequate because he admitted to volitionally operating the vehicle before losing consciousness, causing the pedestrian's death, and leaving the scene without returning. View "State v. Brown" on Justia Law