Justia Minnesota Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant's sentence for aiding an offender as an accomplice after the fact for her role in concealing evidence of a murder that her husband committed, holding that the sentence did not exceed the statutory maximum.Defendant pleaded guilty to aiding an offender to avoid arrest and being an accomplice after the fact. After a sentencing hearing, the district court sentenced Defendant to forty-eight months in prison. The Supreme Court affirmed, holding that the district court did not err in sentencing Defendant to forty-eight months in prison for being an accomplice after the fact. View "State v. Miller" on Justia Law

In this sexual assault case, the Supreme Court granted a writ of prohibition sought by Hope Coalition to prohibit the district court from requiring it to disclose records concerning the alleged victim's counseling to the district court for in camera review, holding that the district court's actions were unreasonable.Hope Coalition invoked the sexual-assault-counselor privilege under Minn. Stat. 595.02, subdivision 1(k) to prevent Defendant's motion in his criminal prosecution seeking disclosure of records concerning the alleged victim's counseling. The district court concluded that compliance with the subpoena to produce the records protected by the sexual-assault-counselor privilege for in camera review was reasonable without addressing that privilege. The Supreme Court reversed, holding (1) the plain language of the statute creates a privilege for sexual assault counselors that cannot be pierced in a criminal proceeding without the victim's consent; and (2) the district court's denial of Hope Coalition's motion to quash the subpoena seeking the records at issue was unauthorized by law. View "State v. Conrad" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing the decision of the district court to deny Defendant's motion to withdraw his guilty plea, holding that Defendant did not meet his burden of proving that his plea was invalid.Defendant pleaded guilty to the charge of violating a domestic abuse no contact order. On appeal, Defendant argued that a manifest injustice occurred that required a plea withdrawal due to his failure personally to admit his previous convictions during his plea colloquy, which made his plea inaccurate. The court of appeals agreed and reversed. The Supreme Court reversed, holding (1) Defendant did not meet his burden to establish a manifest injustice requiring a plea withdrawal or that his plea was otherwise invalid; and (2) therefore, the court of appeals committed reversible error in reversing Defendant's conviction on the basis that his guilty plea was invalid. View "State v. Epps" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree premeditated murder, holding that the State presented sufficient evidence to support the conviction and that the sentence imposed upon Defendant was not unconstitutionally cruel.After a jury trial, Defendant was convicted of first-degree premeditated murder and sentenced to life imprisonment without the possibility of release. The Supreme Court affirmed the conviction and sentence, holding (1) there was sufficient evidence in the record to support the conviction; and (2) a mandatory sentence of life without the possibility of release is not unconstitutionally cruel under Minn. Const. art. I, section 5 when imposed on a twenty-one-year-old defendant who has been convicted of first-degree premeditated murder. View "State v. Hassan" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree felony murder and his sentence of life imprisonment as well as the denial of his petition for postconviction relief, holding that sufficient evidence supported the conviction and that Defendant's constitutional and ineffective assistance of counsel challenges failed.After he was convicted Defendant filed a direct appeal. The Supreme Court stayed the appeal to allow Defendant to pursue postconviction relief. The district court denied the petition following an evidentiary hearing. The Supreme Court lifted the stay, consolidated Defendant's appeal, and affirmed, holding (1) the evidence was sufficient to support the conviction; (2) Defendant's arguments related to a witness's identification testimony failed; (3) Defendant's right to a speedy trial was not violated; and (4) Defendant's claims of ineffective assistance of counsel were without merit. View "State v. Jones" on Justia Law

The Supreme Court affirmed the order of the court of appeals remanding this case to the district court to have two jurors who testified in private during a post-trial Schwartz hearing questioned again in a public hearing, holding that the court of appeals properly concluded that the district court erred when it closed the first part of the Schwartz hearing to the public.After a jury trial, Defendant was found guilty of second-degree murder. Thereafter, one of the jurors suggested that she might have introduced extraneous information during deliberations. The district court held a Schwartz hearing to determine the effect of this information on the verdict but divided the hearing into two parts because of jurors' scheduling conflicts. The court of appeals ruled that the district court erred when it closed the first part of the Schwarz hearing to the public. The Supreme Court affirmed, holding (1) a post-trial Schwartz hearing is more analogous to a pretrial suppression hearing; and (2) the appropriate remedy was to remand to conduct a public Schwartz hearing. View "State v. Jackson" on Justia Law

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

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

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

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