Justia Minnesota Supreme Court Opinion Summaries

In this case, the appellant, Deshawn Woolridge Carter, was convicted of first-degree criminal sexual conduct. At the time of the offense, he was under court-ordered conditions following a guilty plea to a felony theft offense, with adjudication stayed. During sentencing, the district court included a custody status point in his criminal history score, which increased the presumptive sentencing range. The appellant argued that because no conviction had been entered for his felony theft offense, he was not on "probation," and the district court had not "entered" his guilty plea.The district court concluded that the appellant was on probation when he committed the current offense, satisfying the requirements of Minnesota Sentencing Guidelines 2.B.2.a. The court included one custody status point in his criminal history score, resulting in a higher presumptive sentencing range. The court of appeals affirmed this decision, holding that the guidelines unambiguously authorized the assignment of a custody status point for an offense committed while on probation under a stay of adjudication.The Minnesota Supreme Court reviewed the case and affirmed the lower court's decision. The court held that the term "probation" in the guidelines includes court-ordered conditions under a stay of adjudication following a guilty plea. Additionally, the phrase "entry of a guilty plea" refers to the act of pleading guilty on the record, not the court's acceptance and recording of the plea. Therefore, the district court did not err in assigning a custody status point to the appellant's criminal history score. View "State of Minnesota vs. Carter" on Justia Law

Blair Benedict Oberton was found in direct criminal contempt of court for a profanity-laced outburst during a judicial proceeding, partially directed at the district court judge. The district court summarily imposed a 180-day sentence, the maximum allowed under its inherent authority. Oberton appealed, arguing that the district court was required to make a finding of extraordinary conduct before imposing such a sentence.The district court's decision was affirmed by the Court of Appeals, which concluded that findings were not required to support a 180-day sentence summarily imposed under the court’s inherent authority. By the time the Supreme Court of Minnesota granted Oberton’s petition for review, he had already served his sentence. The Supreme Court determined that the appeal was not moot due to the collateral consequences exception to the mootness doctrine, as the 180-day sentence could impact future sentencing should Oberton be convicted of another offense.The Supreme Court of Minnesota affirmed its holding in State v. Tatum, clarifying that while 180 days is the maximum sentence allowed for direct contempt summarily sentenced for punitive purposes, a district court should limit its sentence to 90 days and a $1,000 fine unless the conduct is extraordinary. The court announced a new rule requiring district courts to make oral or written findings describing the extraordinary conduct within 7 days of the direct contempt order to ensure effective appellate review. The court applied this rule prospectively but concluded that under the unique circumstances of this case, Oberton’s 180-day sentence should be vacated and a 90-day sentence imposed on remand. The decision of the Court of Appeals was reversed, and the case was remanded for further proceedings consistent with the Supreme Court's opinion. View "State of Minnesota vs. Oberton" on Justia Law

Jamal L. Smith was convicted of first-degree intentional murder while committing a drive-by shooting, among other charges, for the fatal shooting of Jay Boughton during a road rage incident. Smith was driving a rented Chevrolet Suburban with two passengers from Chicago to Minnesota. During the trip, Smith brandished a pistol in a video, and later, the Suburban was involved in a road rage incident where Smith allegedly pointed a gun at another driver. On the night of the murder, Smith's Suburban paced Boughton's truck on the highway before a single .45-caliber bullet was fired from the Suburban, striking Boughton in the neck and causing his death.The Hennepin County District Court denied Smith's motion to dismiss the indictment based on the racial composition of the grand jury and admitted evidence of Smith's prior bad acts under the immediate episode exception. A jury found Smith guilty, and he was sentenced to life with the possibility of release for the murder charge and a concurrent sentence for possession of ammunition or a firearm after being convicted of a crime of violence. Smith appealed, arguing judicial bias, ineffective assistance of counsel, improper jury pool composition, erroneous admission of prior bad acts, and insufficient evidence to prove he fired the fatal shot.The Minnesota Supreme Court reviewed the case and found that Smith failed to demonstrate judicial bias or ineffective assistance of counsel. The court also held that Smith did not show that Black persons were underrepresented in the jury pool or that any underrepresentation resulted from systematic exclusion. The court ruled that the district court did not abuse its discretion in admitting evidence of Smith's prior bad acts, as it was admissible under the Spreigl exception or as direct or corroborative evidence of a charged crime. Finally, the court concluded that the only reasonable inference from the circumstances proved was that Smith fired the fatal shot. The court affirmed the judgment of convictions. View "State v. Smith" on Justia Law

In December 2015, Sean Michael Wocelka’s daughter disclosed during a forensic interview that her father had touched her intimate parts using a toy giraffe. The incident occurred shortly before Christmas. Officers found the toy giraffe in Wocelka’s home, and he was charged with three counts of second-degree criminal sexual conduct. At trial, Wocelka’s daughter testified consistently with her initial statement. The jury found Wocelka guilty of two counts of second-degree criminal sexual conduct for the December 2015 incident.The district court convicted Wocelka of one count under Minnesota Statutes section 609.343, subdivision 1(a), which criminalizes sexual contact with a complainant under 13 years old by an actor more than 36 months older. Wocelka petitioned for postconviction relief, arguing that his conduct did not meet the statutory definition of “sexual contact.” The district court denied the petition as untimely and on the merits. The Minnesota Court of Appeals affirmed the district court’s decision on the merits without addressing the timeliness issue.The Minnesota Supreme Court reviewed the case to determine whether the use of an object to make contact with a complainant’s intimate parts constitutes “sexual contact” under Minnesota Statutes section 609.341, subdivision 11(a)(i). The court held that the term “touching” includes bringing an object into contact with the complainant’s intimate parts. Therefore, the court affirmed that Wocelka’s actions met the statutory definition of “sexual contact” and upheld his conviction for second-degree criminal sexual conduct. View "Wocelka vs. State of Minnesota" on Justia Law

The case revolves around Harry Jerome Evans, who was convicted of first-degree murder of a peace officer in 2006. The officer, Sergeant Gerald Vick, was shot during an undercover investigation at a bar in Saint Paul. Evans was identified as the shooter by Sergeant Joseph Strong, who was with Vick at the time, and by a trial witness. Evans's cousin, A.K., also testified that Evans had shot Vick. Evans claimed that A.K. was the actual shooter and that Vick was not performing official duties at the time of the shooting due to his intoxication. Evans was sentenced to life in prison without the possibility of release.Evans appealed his conviction multiple times in both state and federal courts. His appeals were consistently denied, with courts rejecting his claims of ineffective assistance of counsel, prosecutorial misconduct, and allegations that A.K. had admitted to being the actual shooter. Evans also filed petitions for postconviction relief and motions to correct his sentence, all of which were denied.In the current petition, Evans sought postconviction relief, arguing that his petition met the newly-discovered-evidence and interests-of-justice exceptions to the statutory time bar. The district court denied the petition, concluding that the facts alleged in the petition did not meet either exception. Evans appealed this decision.The Minnesota Supreme Court affirmed the district court's decision. The court found that Evans's petition did not meet the requirements of the newly-discovered-evidence exception, as the evidence was either not new, not exonerating, or was known or knowable by Evans at the time of trial. The court also found that Evans's petition did not meet the requirements of the interests-of-justice exception, as Evans did not allege that an injustice prevented him from filing his petition in a timely manner. View "Evans vs. State" on Justia Law

The case revolves around the appellant, McKinley Juner Phillips, who was convicted of first-degree premeditated murder and second-degree intentional murder for the stabbing death of his wife, Shavon Phillips. The appellant had conceded at trial that he caused the death of his wife but had requested that the jury be given instructions for first-degree heat-of-passion manslaughter in addition to the instructions for first-degree premeditated murder and second-degree intentional murder. The district court denied the requested instruction, reasoning that the evidence did not support a heat-of-passion instruction.The appellant appealed the district court's decision, arguing that the court committed reversible error by denying the requested instruction. The appellant's argument was based on the premise that the jury's finding of premeditation does not necessarily preclude a finding of heat-of-passion.The Minnesota Supreme Court, however, affirmed the district court's decision. The Supreme Court held that the appellant was not prejudiced by the district court’s decision not to instruct the jury on first-degree heat-of-passion manslaughter because the court gave instructions on both first-degree premeditated murder and second-degree intentional murder and the jury found the appellant guilty of first-degree premeditated murder. The court reasoned that the mental states of premeditation and heat of passion cannot coexist, and since the jury found the appellant guilty of premeditated murder, it would not have found him guilty of heat-of-passion manslaughter. View "Phillips v. State" on Justia Law

The case involves Angel Ignacio Sardina-Padilla, who was convicted of first-degree premeditated murder for the death of Jose Genis Cuate. Sardina-Padilla appealed the conviction, arguing that the district court erred in denying his motion to suppress evidence obtained from a warrant to search his Facebook accounts. He claimed that the warrant application failed to establish probable cause and did not satisfy minimal constitutional requirements for particularity. He also argued that the district court abused its discretion by summarily denying his petition for postconviction relief, which alleged ineffective assistance of counsel.The district court had denied Sardina-Padilla's motion to suppress the evidence obtained from the June warrant, concluding that the totality of the circumstances described in the June warrant application suggested that the accounts likely contained relevant evidence. The court also concluded that the June warrant satisfied minimal constitutional requirements for particularity.On appeal, the Supreme Court of Minnesota affirmed the district court's decision. The court found that the district court did not err in finding that the warrant application alleged that Sardina-Padilla asked someone to delete his Facebook account during a jail call. The court also concluded that the June warrant was sufficiently particular, considering the circumstances of the case, the nature of the crimes under investigation, and whether the officers could have provided a more precise description of the evidence sought. Finally, the court concluded that there was no reasonable probability that the trial’s outcome would have been different if counsel had successfully challenged the tracking data, and therefore, the district court did not abuse its discretion by summarily denying Sardina-Padilla’s petition for postconviction relief. View "State v. Sardina-Padilla" on Justia Law

The defendant, Sylvester Jones, was charged with third-degree criminal sexual conduct, using force to accomplish sexual penetration. After initially pleading not guilty, Jones later entered a guilty plea to the third-degree criminal sexual conduct charge in return for dismissal of other charges. However, during the plea hearing, Jones made a statement on record denying that he had committed the offense. Despite this, the judge found Jones’s factual basis sufficient to support his guilty plea, accepted it, and adjudged Jones guilty. Jones did not request withdrawal of his guilty plea at the continued sentencing hearing, and the district court sentenced Jones to 153 months in prison.On appeal, Jones argued that his unaddressed assertion of innocence made the factual basis for his guilty plea inaccurate. The court of appeals affirmed the lower court's decision, reasoning that Jones’s assertion of innocence during the plea hearing did not invalidate his plea because after he made the assertion, Jones admitted to the factual basis for the guilty plea through affirmative responses to defense counsel’s leading questions.The Minnesota Supreme Court disagreed with the lower courts. The court found that Jones’s guilty plea was inaccurate because he made a statement at the plea hearing that negated at least one element of the charged offense, and his guilty plea was not sufficiently rehabilitated because defense counsel subsequently used solely leading questions to elicit the necessary admissions for the factual basis. The court concluded that Jones is entitled to withdraw his plea to correct a manifest injustice under Minn. R. Crim. P. 15.05, subd. 1. The court reversed the decision of the court of appeals and remanded the case to the district court for further proceedings. View "State of Minnesota vs. Jones" on Justia Law

Michael Joseph Letourneau was charged with two counts of first-degree criminal sexual conduct. He was already incarcerated for unrelated reasons, which made him subject to the Uniform Mandatory Disposition of Detainers Act (UMDDA). This act allows incarcerated individuals to demand the speedy disposition of any pending criminal charges. Letourneau signed a formal request for his trial to commence within 6 months, as provided by the Act. However, during pretrial proceedings, Letourneau had multiple changes of counsel and a continuance due to defense counsel’s conflict that delayed resolution of pretrial matters. The district court found good cause to begin his trial in October, past the deadline otherwise required by the Act.The district court's decision to delay the trial was appealed to the Minnesota Court of Appeals, which affirmed the lower court's decision. The appellate court held that the district court did not abuse its discretion in finding good cause for a continuance because the delay was minimal and because Letourneau did not allege any prejudice caused by the delay.The case was then brought before the Minnesota Supreme Court. The Supreme Court affirmed the decision of the Court of Appeals, holding that the district court did not abuse its discretion in delaying the trial. The court noted that the district court had found good cause for the delay, citing changes of counsel, administrative delays, and scheduling issues. The court also noted that Letourneau's counsel did not object to the new trial date or the district court's finding of good cause to continue the trial date. The Supreme Court concluded that Letourneau’s right to a speedy disposition under the Act was not violated, and the district court’s reasonable continuance of the trial was not an abuse of its discretion. View "State of Minnesota vs. Letourneau" on Justia Law

The case involves Anthony James Trifiletti, who was convicted of second-degree unintentional felony murder. The conviction followed a second trial after the first ended in a mistrial due to a deadlocked jury. During the second trial, one of the State’s witnesses was exposed to COVID-19 and was deemed unavailable to testify in person. The district court allowed the transcript of her testimony from the first trial to be read into the record instead of live testimony. Trifiletti appealed, arguing that this violated his right to confrontation under the Sixth Amendment to the United States Constitution and Article I, Section 6, of the Minnesota Constitution.The Minnesota Supreme Court held that the district court erred in determining that the witness was unavailable under the Confrontation Clause. The court found that the State failed to establish that the witness would not have been available to testify in person at some reasonable point in time during the trial. The court also rejected the State's argument that Trifiletti invited the error by choosing to have the witness's prior testimony read aloud for the jury rather than having her testify via video. However, the court concluded that the error was harmless beyond a reasonable doubt, as the jury's determination that Trifiletti did not act in self-defense was surely unattributable to the witness's testimony. Therefore, the court reversed the decision of the court of appeals. View "State of Minnesota vs. Trifiletti" on Justia Law