Articles Posted in Criminal Law

The Supreme Court vacated Defendant’s sentence of 135 months in prison for his conviction for first-degree possession of methamphetamine, holding that resentencing was required under sentencing grid as amended by the Drug Sentencing Reform Act (DSRA). The DSRA, which took effect after Defendant committed his offense, reduced the presumptive sentencing range under the Minnesota Sentencing Guidelines drug offender sentencing grid for Defendant’s crime. The Supreme Court held that Defendant must be resentenced under the DSRA-amended sentencing grid, holding that the amelioration doctrine required that Defendant be resentenced. View "State v. Otto" on Justia Law

The Supreme Court reversed the court of appeals affirming the district court’s dismissal of the State’s amended complaint against Minnesota School of Business and Globe University (the Schools). The State alleged that the Schools charged usurious interest rates and made loans without the required license for making private student loans at interest rates of up to eighteen percent. The State’s amended complaint sought permanent statutory injunctive relief to stop the Schools from engaging in unlicensed and usurious lending. The district court granted summary judgment for the Schools. The court of appeals affirmed. The Supreme Court reversed, holding (1) the Schools charged usurious interest rates in violation of Minn. Stat. 334.01(1); and (2) the Schools were required to obtain a lending license under Minn. Stat. 56.01(a), and their failure to do so meant that they engaged in unlicensed lending. View "State v. Minnesota School of Business, Inc." on Justia Law

The Supreme Court vacated Defendant’s sentence of 161 months in prison for his conviction of first-degree possession of methamphetamine, holding that resentencing was required under sentencing grid as amended by the Drug Sentencing Reform Act (DSRA). The DSRA, which took effect while Defendant’s case was on appeal, reduced the presumptive sentencing range under the Minnesota Sentencing Guidelines drug offender sentencing grid for Defendant’s crime. The Supreme Court held that Defendant must be resentenced under the DSRA-amended sentencing grid because the amelioration doctrine applied to Defendant, whose conviction was not yet final when the DSRA took effect. View "State v. Kirby" on Justia Law

The Supreme Court affirmed Appellant’s conviction for two counts of theft by false representation, holding that, even assuming that the trial court’s omission of the phrase “with intent to defraud” from the jury instructions on the elements of theft by false representation was error, the error was harmless. Appellant's convictions were based on her acts of submitting timesheets and receiving payments for personal care assistant services that she did not perform. The court of appeals affirmed the convictions, concluding that, when viewed as a whole, the district court’s jury instructions fairly and adequately explained the law. The Supreme Court agreed, holding that any alleged error in the jury instructions was harmless beyond a reasonable doubt. View "State v. Schoenrock" on Justia Law

The Supreme Court reversed Appellant’s conviction of first-degree driving while impaired, holding that Appellant’s 2005 gross-misdemeanor conviction of criminal vehicular operation was not a qualified prior impaired driving incident and was therefore improperly used to enhance Appellant’s offense to a first-degree crime. Appellant’s current offense of driving while impaired was enhanced to a first-degree crime based on the existence of three prior impaired-driving convictions, including the 2005 conviction at issue. The court of appeals affirmed, ruling that Appellant’s current offense was properly charged and adjudicated as a first-degree crime because his 2005 conviction was a qualifying offense. In reversing the court of appeals, the Supreme Court held that the evidence was insufficient to convict Appellant of first-degree driving while impaired because, under the plain language of Minn. Stat. 169A.03, subd. 20, Appellant’s 2005 criminal vehicular operation conviction did not qualify as a prior impaired driving conviction. View "State v. Smith" on Justia Law

Minn. R. Evid. 1101 requires application of the Minnesota Rules of Evidence to restitution hearings. After a jury trial, Defendant was found guilty of aggravated forgery. At a restitution hearing, Defendant objected to the admissibility of certain e-mails on hearsay grounds. The trial court overruled the objection, concluding that the Rules of Evidence did not apply. The court of appeals affirmed the district court’s evidentiary rulings, concluding that the evidentiary rules do not apply to restitution hearings because the obligation to pay restitution is a part a sentence and the Rules of Evidence do not apply to sentencing proceedings. The Supreme Court reversed, holding that the Rules of Evidence apply to all cases and proceedings unless the rules provide otherwise, and because the language of rule 1101(b)(3) does not preclude their application to restitution hearings, the Minnesota Rules of Evidence apply to such hearings. View "State v. Willis" on Justia Law

The Supreme Court affirmed Defendant’s first-degree murder conviction in connection with the death of his two-year-old niece. This appeal followed from Defendant’s third trial, which involved the same five counts of murder as Defendant’s second trial. The jury found Defendant guilty of five counts of murder. The district court sentenced Defendant on the first count - first-degree murder while committing criminal sexual conduct - imposing the mandatory sentence of life in prison without the possibility of release. The Supreme Court affirmed but remanded to the district court for correction of the sentencing order, holding (1) two alleged errors in the district court’s evidentiary rulings did not affect the verdict; (2) the prosecutor did not commit plain error during closing argument; (3) the alleged errors, when considered cumulatively, did not deny Defendant a fair trial; and (4) the district court’s sentencing order erroneously stated that Defendant was convicted of all five murder charges. View "State v. Fraga" on Justia 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