Justia Minnesota Supreme Court Opinion Summaries

Police officers responded to a report that a man in a yellow and black coat was pointing a handgun at people at a Minneapolis light rail station. They found the suspect inside a nearby pizza restaurant, where several other people, including 16-year-old C.T.B., were standing nearby. An officer, based on his experience that weapons can be passed among individuals in a group, conducted a pat-frisk of C.T.B. and found a handgun in his possession. C.T.B. was charged with unlawful possession of a firearm by a minor and moved to suppress the handgun, arguing that the officers lacked reasonable, articulable suspicion to frisk him.The Hennepin County District Court denied the motion to suppress, finding that C.T.B.’s proximity to the original suspect and the officer’s experience justified the frisk. After a stipulated facts trial, the court found C.T.B. guilty and stayed adjudication. The Minnesota Court of Appeals affirmed, reasoning that the totality of the circumstances—including the possibility that the original suspect had handed off the firearm—made the frisk of C.T.B. objectively reasonable.The Minnesota Supreme Court reviewed the case and held that the officers did not have reasonable, articulable suspicion that C.T.B. was armed and dangerous when they conducted the pat-frisk. The court clarified that mere proximity to a suspect in an alleged crime, even when combined with general knowledge that weapons can be passed among group members, is not sufficient to justify a warrantless pat-frisk under Terry v. Ohio. The court reversed the decision of the court of appeals and remanded the case to the district court for further proceedings. View "In the Matter of the Welfare of: C.T.B" on Justia Law

A man was involved in a single-vehicle accident in Minnesota, after which law enforcement discovered a self-assembled pistol in his car that lacked a serial number. He admitted to possessing the firearm and not having a permit to carry it. The firearm, a Glock 19-style pistol, was constructed from parts purchased in 2021, before new federal regulations required serial numbers on certain parts kits. He was charged with felony possession of a firearm without a serial number under Minnesota law, as well as carrying a pistol without a permit.The Anoka County District Court granted the defendant’s motion to dismiss the charge related to the serial number, finding that while he knowingly possessed a firearm without a serial number, the relevant Minnesota statute was unconstitutionally vague as applied. The State appealed. The Minnesota Court of Appeals reversed the district court, holding that the statute plainly applied to any firearm lacking a serial number, regardless of whether federal law required one, and remanded the case for further proceedings.The Supreme Court of Minnesota reviewed the case. It held that Minnesota Statutes section 609.667(3) criminalizes possession of a firearm without a serial number only if federal law requires that the firearm have a serial number. The court reasoned that Minnesota has no independent serial number regime and that the statute’s reference to federal law means only firearms required by federal law to have serial numbers are covered. Because the defendant’s firearm was not required by federal law to have a serial number, the Supreme Court of Minnesota reversed the decision of the court of appeals and remanded the case to the district court. View "State v. Vagle" on Justia Law

In 2014, Diamond Lee Jamal Griffin was convicted in Hennepin County District Court of first-degree intentional felony murder while committing or attempting to commit aggravated robbery, stemming from the fatal shooting of Francisco Benitez-Hernandez in Minneapolis in July 2013. Griffin appealed, and the Minnesota Supreme Court affirmed his conviction, concluding that the evidence supported a reasonable inference that Griffin shot Benitez-Hernandez with intent to kill. Griffin's subsequent petitions for postconviction relief were also denied.Griffin filed a preliminary application for relief under a 2023 Minnesota law that allows individuals convicted of certain felony murder offenses under an aiding-and-abetting theory to have their sentences vacated if they can show they neither caused the death nor intentionally aided in causing the death. The Hennepin County District Court denied Griffin's application, concluding that there was no reasonable probability that Griffin was entitled to relief under the new law, based on the application, supporting materials, and previous court decisions.The Minnesota Supreme Court reviewed the case and addressed two primary issues: the appropriate standard of review for appeals under the new law and whether the district court abused its discretion in denying Griffin's application. The court concluded that the standard of review is abuse of discretion, given the text of the law and its treatment of the application as a postconviction proceeding. The court then determined that the district court did not abuse its discretion in denying Griffin's application, as the established facts and prior court decisions supported the conclusion that Griffin caused the death of Benitez-Hernandez. The Minnesota Supreme Court affirmed the district court's decision. View "State of Minnesota vs. Griffin" on Justia Law

Erick Dewaun Haynes pleaded guilty to first-degree felony murder under an aiding-and-abetting theory. He admitted to planning a confrontation with his ex-girlfriend's new partner, R.C., involving two juveniles armed with handguns. The plan resulted in the juveniles shooting and killing his ex-girlfriend, Zaria McKeever, instead. Haynes received a mandatory life sentence with the possibility of parole. The plea agreement did not specifically address restitution.The district court ordered Haynes to pay $7,500 in restitution to the Minnesota Crime Victims Reimbursement Board (CVRB) and reserved the determination of additional restitution for 90 days. Haynes did not challenge this order. The State later sought additional restitution for McKeever’s family members, totaling $17,026.06. Haynes did not object to this request either, and the district court granted it.Haynes appealed the restitution award, arguing that the district court failed to make necessary factual findings and that some restitution recipients were not "victims" under the statute. The Minnesota Supreme Court reviewed the case and concluded that Haynes forfeited his challenges by not raising them in the district court. The court emphasized that challenges to restitution must be made within 30 days of the order, as outlined in Minnesota Statutes section 611A.045, subdivision 3. Since Haynes did not follow this procedure, his challenges were not properly before the court.The Minnesota Supreme Court affirmed the district court’s restitution award, holding that Haynes forfeited his right to challenge the restitution by failing to object in the district court. View "State of Minnesota vs. Haynes" on Justia Law

James Nyonteh was convicted of first-degree premeditated murder, first-degree domestic abuse murder, second-degree intentional murder for killing his wife, and first-degree criminal sexual conduct for sexually abusing his minor stepdaughter. The district court sentenced him to life imprisonment without the possibility of release and a consecutive prison term of 144 months. Nyonteh appealed his convictions, arguing that the district court erred by dismissing a juror for sleeping during the trial, that the State failed to prove beyond a reasonable doubt that his stepdaughter feared imminent great bodily harm during the sexual assaults, and that the district court erred by entering multiple convictions for the same conduct against the same victim.The district court had excused a juror who repeatedly fell asleep during the trial, despite efforts to keep him awake and engaged. The court determined that the juror's inability to stay awake compromised the fairness of the trial. The jury found Nyonteh guilty on all charges, and the district court entered convictions for first-degree premeditated murder and first-degree criminal sexual conduct, but the warrant of commitment also included convictions for first-degree domestic abuse murder and second-degree intentional murder.The Minnesota Supreme Court reviewed the case and held that the district court did not abuse its discretion in excusing the sleeping juror, as the juror's conduct raised concerns about the fairness of the trial. The court also found that the evidence was sufficient to support Nyonteh's conviction for first-degree criminal sexual conduct, as the circumstances proved that his stepdaughter reasonably feared imminent great bodily harm.However, the court agreed with Nyonteh that the district court erred by entering multiple convictions for the same conduct against the same victim. The court reversed the additional convictions for first-degree domestic abuse murder and second-degree intentional murder and remanded the case to the district court to vacate those convictions. The court affirmed the remaining convictions and sentences. View "State of Minnesota vs. Nyonteh" on Justia Law

Ricky Darnell Waiters was convicted of first-degree felony murder and attempted first-degree felony murder following a shooting incident in Winona County. His convictions were affirmed on direct appeal. Waiters subsequently filed multiple petitions for postconviction relief, all of which were denied by the district court. In his latest petition, Waiters sought reversal of his convictions or a new trial, citing claims of ineffective assistance of counsel, prosecutorial misconduct, erroneous evidentiary rulings, and insufficient evidence.The district court summarily denied Waiters's latest petition without a response from the State. Waiters appealed, and the Supreme Court of Minnesota remanded the case for further proceedings, as the basis for the district court's decision was unclear. On remand, the State argued that Waiters's claims were both procedurally and time-barred. The district court agreed and again summarily denied the petition, providing a written order with its reasoning. Waiters appealed this decision.The Supreme Court of Minnesota reviewed the case and affirmed the district court's summary denial of Waiters's petition for postconviction relief. The court held that Waiters's petition was time-barred under Minnesota Statutes section 590.01, subdivision 4, as it was filed more than two years after the appellate court's disposition of his direct appeal. The court also found that the exceptions to the time bar, including newly discovered evidence and new interpretations of law, did not apply to Waiters's claims. Consequently, the court concluded that the district court did not abuse its discretion in denying the petition without an evidentiary hearing. View "Waiters vs. State of Minnesota" on Justia Law

A man entered a senior living apartment building in Minneapolis, where he had previously visited several times, and asked to see a vacant apartment. After being shown the apartment by a manager, he pushed her into a closet, choked her, and brandished a knife. The victim fought back and screamed for help, after which the man stopped, apologized, and left. He was later arrested and, after being read his Miranda rights, confessed to police that he had planned to rape the victim but did not follow through. The man was charged with attempted first-degree criminal sexual conduct.The Hennepin County District Court denied the defendant’s motion to suppress his confession, found him guilty of attempted first-degree criminal sexual conduct causing personal injury using force or coercion, and sentenced him to prison. The court found him not guilty of the charge involving use of a dangerous weapon. The defendant appealed, arguing that his conviction violated Minnesota’s corpus delicti statute, which prohibits convictions based solely on a confession. The Minnesota Court of Appeals reversed the conviction, holding that for attempt crimes, the statute requires independent evidence of both intent and a substantial step toward the crime, and found that only the confession established intent.The Minnesota Supreme Court reviewed the case and held that the corpus delicti statute is satisfied for both completed and attempt offenses when there is independent evidence that reasonably tends to prove the defendant committed the charged offense. The court concluded that the State’s evidence, independent of the confession, reasonably tended to show the defendant committed attempted first-degree criminal sexual conduct. The Supreme Court reversed the Court of Appeals’ decision and remanded the case for consideration of the defendant’s remaining appellate arguments. View "State v. Hill" on Justia Law

Joel Marvin Munt was convicted of first-degree premeditated murder and other related offenses in 2011 for the murder of his ex-wife, Svetlana Munt. He was sentenced to life in prison without the possibility of release. Munt filed his third petition for postconviction relief, arguing that the United States Supreme Court’s decision in Dobbs v. Jackson Women’s Health Organization rendered his conviction invalid on equal protection grounds. He also raised claims of entrapment, trial counsel’s disregard of his “defense objective of choice,” and witness tampering.The district court summarily denied Munt’s petition without a hearing. Munt appealed to the Minnesota Supreme Court. The court noted that Munt’s convictions became final in 2013 and that his current petition, filed in October 2023, was untimely under Minn. Stat. § 590.01, subd. 4(a)(2). The court also found that the Dobbs decision did not change the law as applied to Munt’s case, as his conviction for first-degree murder was unrelated to abortion laws.The Minnesota Supreme Court held that Munt’s claims were time-barred and that he did not establish a new interpretation of law that was retroactively applicable to his case. The court also concluded that Munt’s other claims, including witness tampering, trial counsel’s disregard of his “defense objective of choice,” and entrapment, were untimely and did not meet the interests-of-justice exception. The court affirmed the district court’s decision to deny Munt’s petition for postconviction relief. View "Munt v. State" on Justia Law

Almost 30 years after his conviction for first-degree murder was affirmed, Nantambu Noah Kambon filed a petition for postconviction relief, raising several issues and requesting a new trial. The district court denied the petition without an evidentiary hearing, citing its untimeliness. Kambon appealed, raising two issues from the district court and introducing a new argument on appeal.The district court found Kambon's petition untimely under Minnesota Statutes section 590.01, which requires postconviction petitions to be filed within two years after the judgment of conviction or the appellate court’s disposition on direct appeal. Since Kambon's conviction became final before August 1, 2005, the two-year limitation ended on August 1, 2007. The district court also rejected Kambon's argument that his claim qualified under the new interpretation of law exception, reasoning that the petition was filed nearly 30 years after his direct appeal concluded, and all issues raised were known or should have been known during previous petitions.The Minnesota Supreme Court reviewed the case and affirmed the district court's decision. The court held that Kambon's claims were untimely and did not qualify for any exceptions to the two-year time limitation. The court also rejected Kambon's new argument that the United States Supreme Court's decision in Loper Bright Enterprises v. Raimondo, which overruled Chevron U.S.A., Inc. v. Natural Resources Defense Council, Inc., applied to his case. The court clarified that the Chevron doctrine never applied to deference afforded to prior court decisions and that nothing in Chevron prevented Kambon from bringing his claims before 2007. Therefore, the court concluded that Loper Bright did not constitute a new interpretation of law that applied retroactively to Kambon's case. View "Kambon v. State" on Justia Law

Clifford Robert Letourneau, III, was charged with first-degree criminal sexual conduct under Minnesota Statutes section 609.342, subdivision 1(d), which criminalizes nonconsensual sexual penetration when the actor uses force, defined as the infliction of bodily harm. The complaint alleged that Letourneau arrived at K.L.'s home, and without consent, inserted his penis into her vagina, causing her to cry and bleed due to vaginal tearing.The district court dismissed the charge for lack of probable cause, concluding that the complaint did not allege facts showing that Letourneau used force to accomplish the act of sexual penetration. The court interpreted the statute to require the use of force to accomplish the act of penetration, not merely in conjunction with it.The Minnesota Court of Appeals reversed the district court's decision, interpreting the statute to require the use of force either before or during the act of sexual penetration, not necessarily to accomplish it. The court of appeals determined that the plain language of the statute criminalizes nonconsensual sexual penetration when the actor uses force either before or during the act.The Minnesota Supreme Court affirmed the court of appeals' decision, concluding that the plain language of section 609.342, subdivision 1(d) criminalizes nonconsensual sexual penetration when the actor uses force either before or during the act. The court held that the statute does not require the force to be used to accomplish the act of penetration. The court found that the facts alleged in the complaint, including K.L.'s statements about the bleeding and vaginal tearing caused by Letourneau's actions, established probable cause that Letourneau used force before or during the act of sexual penetration. View "State of Minnesota vs. Letourneau" on Justia Law