Justia Minnesota Supreme Court Opinion Summaries

The case involves Jerry Arnold Westrom, who was convicted of first-degree premeditated murder and second-degree intentional murder. The victim, Jeanie Childs, was found stabbed to death in her apartment in 1993. The case went cold until 2018 when police began working with the FBI to review Childs’ murder. They sent a DNA sample from the crime scene to DNA Solutions, Inc. to create a single nucleotide polymorphism (SNP) profile that could be compared with profiles on commercial genealogical databases to identify the source’s relatives. A potential match was located on MyHeritage that appeared to be a first cousin to the source of the crime scene DNA. Law enforcement then used the match to construct a family tree that identified Westrom as the likely source.The district court denied Westrom’s motion to suppress all evidence stemming from the police’s comparison of the SNP profile created from DNA gathered from the crime scene with other profiles on commercial genealogical databases. His motion also contested the admissibility of evidence obtained through the STR analysis of DNA taken from his discarded napkin. The district court concluded that no search had occurred because Westrom held no expectation of privacy in the information contained within his DNA when police only used his DNA for the purpose of identification.The Minnesota Supreme Court affirmed Westrom’s conviction of first-degree premeditated murder. The court found that the district court did not err in concluding that the genetic analysis of a napkin discarded by Westrom was not a search under the United States or Minnesota Constitutions. The court also found that the circumstantial evidence was sufficient to support Westrom’s convictions. However, the court reversed the second-degree murder conviction and remanded to the district court to vacate that conviction, as it was an error to convict Westrom of both first-degree felony murder and the lesser-included offense of second-degree intentional murder. View "State of Minnesota vs. Westrom" on Justia Law

Tyson Joe Hinckley was convicted of first-degree arson, second-degree burglary, and theft of a motor vehicle. Hinckley had stolen a vehicle from a garage and started a fire that damaged the garage and an adjacent home. He sought to assert a mental-illness defense at trial, submitting multiple psychological reports attesting to his mental illness at the time of his offenses. However, the district court rejected the mental-illness defense, concluding that Hinckley had not provided sufficient evidence that he was acting under a defect in reasoning caused by mental illness at the time of the offenses. Hinckley was found guilty at trial, and the court of appeals affirmed the convictions.The Minnesota Supreme Court reversed the lower courts' decisions, holding that the district court had abused its discretion by denying Hinckley the right to assert a mental-illness defense. The Supreme Court found that the psychological reports submitted by Hinckley provided sufficient evidence to establish a prima facie case of a mental-illness defense. The court concluded that the district court's error was not harmless beyond a reasonable doubt, as it could not be certain that the jury's verdict was surely unattributable to the error. The case was remanded for further proceedings consistent with the Supreme Court's opinion. View "State of Minnesota vs. Hinckley" on Justia Law

Edbert Neal Williams was convicted of first-degree murder and first-degree attempted murder in the death of Genelda Campeau and the attack on her adult granddaughter, S.C. Williams was sentenced to life in prison for murder and received a 180-month consecutive sentence for attempted murder. He appealed, and his convictions were affirmed. In this postconviction proceeding, Williams seeks a new trial or an evidentiary hearing based on new DNA evidence not available at the time of trial. Williams asserts the DNA evidence exonerates him and implicates an alternative perpetrator.Williams had previously filed multiple postconviction relief petitions, all of which were denied. In 2019, Williams filed a motion seeking forensic testing of evidence from the 1996 crime scene. The district court granted the motion, and the Bureau of Criminal Apprehension (“BCA”) analyzed evidence that it had retained from the crime scene. The BCA released three reports in August 2020, September 2020, and November 2022, and a private lab Williams hired released one report in October 2022. Williams asserts that these reports corroborate his claims that he was not at the scene of the crime when it occurred and that an alternative perpetrator killed Genelda.The district court summarily denied his petition. The court concluded that Williams’s petition was barred by the 2-year time limit for postconviction relief petitions set out in Minnesota Statutes section 590.01, subdivision 4(a) (2022), and that neither the newly-discovered-evidence exception nor the interests-of-justice exception to the time bar applied.The Supreme Court of Minnesota affirmed the district court's decision. The court found that the new DNA evidence did not meet the clear and convincing standard for newly discovered evidence and, in fact, some of the additional testing points towards Williams as the perpetrator rather than excludes him. The court also rejected Williams's claim that he is entitled to relief based on the interests-of-justice exception because his mental illness prevented him from timely filing his petition. The court noted that Williams had been sufficiently competent to file his direct appeal from his conviction, postconviction petitions, and appeals from postconviction petitions. View "Williams vs. State of Minnesota" on Justia Law

The case revolves around the interpretation of Minnesota Statutes section 171.177, subdivision 1, which requires law enforcement officers to inform individuals suspected of driving under the influence that refusal to submit to a blood or urine test is a crime. The respondent, Brian Matthew Nash, was pulled over for suspected impaired driving. After failing field sobriety tests, he was arrested and a state trooper obtained a search warrant for a blood or urine test. The trooper informed Nash that refusal to take a test is a crime, and Nash complied. His blood test revealed the presence of a controlled substance, leading to the revocation of his driving privileges.Nash sought judicial review of his license revocation, arguing that the trooper's advisory did not comply with the statutory requirement. The district court rejected Nash's arguments and sustained the revocation. On appeal, the court of appeals reversed, finding that the advisory given to Nash was misleading and an inaccurate statement of law.The Minnesota Supreme Court disagreed with the court of appeals' interpretation of the statute. The court held that the trooper's statement that "refusal to take a test is a crime" satisfied the advisory required by section 171.177, subdivision 1. The court reasoned that the statute does not require officers to inform drivers of all the elements and permutations of what is required before the state may take adverse action against them. The court reversed the decision of the court of appeals and remanded the case for consideration of the other issues raised by Nash in his appeal. View "Nash v. Commissioner of Public Safety" on Justia Law

The case involves the defendant, David Darnell Jones, Jr., who was convicted of second-degree assault after threatening to beat a victim, A.M., while holding a wooden board. The board was approximately 2 inches by 3 inches and 3 feet long. To commit second-degree assault, a defendant must assault another person with a dangerous weapon. The State alleged that Jones brandished the board as a dangerous weapon near the semi-conscious victim, while simultaneously threatening to “beat [A.M.] bloody.” Jones pleaded not guilty and demanded a jury trial.The district court instructed the jury on assault-fear and also instructed the jurors that an object which is neither a firearm nor designed as a weapon can still be considered a dangerous weapon if the defendant intended to use it in a manner likely to produce death or great bodily harm. The jury found Jones guilty of both second- and third-degree assault. The district court convicted Jones of both counts and sentenced him to 39 months in prison for second-degree assault. A divided panel of the court of appeals affirmed Jones’s conviction for second-degree assault but reversed his third-degree assault conviction as a lesser-included offense.The Minnesota Supreme Court affirmed the decision of the court of appeals. The court concluded that Jones’s statements expressing his plan to harm A.M., made while the assault was occurring and as Jones was brandishing the board, are direct evidence of his intent to use the board in a manner likely to produce great bodily harm. The court further concluded that, based on the direct evidence of Jones’s intended use of the board, a jury could reasonably conclude that the board was a dangerous weapon. View "State vs. Jones" on Justia Law

The case revolves around a murder conviction. On February 23, 2021, a bar shooting resulted in the death of Raymond Renteria-Hobbs and injury to another victim, M.P. Police identified Andrew Vernard Glover as the suspect based on security footage showing him at the bar on the night of the murder and his interactions with Renteria-Hobbs before the shooting. The police arrested Glover and, upon searching his residence, found the hat he wore on the night of the shooting, a loaded firearm, and ammunition.At trial, Glover challenged his arrest and the subsequent search of his residence. However, the court held that the police had probable cause to arrest Glover, and the search warrant application for his residence did not materially misrepresent information.Glover also sought to introduce evidence of prior crimes committed by an alleged alternative perpetrator, but the court denied his request, finding those crimes were neither relevant nor material to the charged offense. Glover also argued that the court violated his confrontation rights by denying his request to cross-examine the lead investigator about whether police had investigated unnamed suspects from a prior shooting of one of the victims. The court rejected this argument as well.The jury convicted Glover of first-degree murder during a drive-by shooting, drive-by shooting, and ineligible person in possession of a firearm. Glover appealed, but the Supreme Court of Minnesota affirmed the conviction. The court held that the police had probable cause to arrest Glover, the search of his residence was lawful, the court did not abuse its discretion by denying Glover's motion to admit reverse-Spreigl evidence, and Glover's confrontation rights were not violated. View "State of Minnesota vs. Glover" on Justia Law

In this case, the appellant, Lyndon Akeem Wiggins, was convicted of first-degree premeditated murder, attempted first-degree premeditated murder, first-degree intentional murder while committing a felony (kidnapping), and kidnapping, all based on aiding-and-abetting theories of criminal liability. The crimes were related to the kidnapping and murder of realtor Monique Baugh, which involved Wiggins, his girlfriend Elsa Segura, and two other men, Cedric Berry and Berry Davis.On appeal, Wiggins argued that the district court erred by denying his pretrial motion to suppress the cell-site location information (CSLI) for his cell phone as the facts alleged in the warrant application failed to establish probable cause. He also contended that the district court improperly instructed the jury by stating that it could find Wiggins guilty if Wiggins "or another (or others)" satisfied each element of the offense.The Supreme Court of Minnesota held that the district court did not abuse its discretion in denying Wiggins' motion to suppress the CSLI. It found that the totality of the circumstances alleged in the search warrant application established a "fair probability" that evidence of a crime would be found in the CSLI records of Wiggins’s cell phone carrier.However, the Supreme Court found that the district court erred in its instructions to the jury. The court determined that the instructions materially misstated the law as they allowed the jury to convict Wiggins of the charges based on the actions of others without reaching the issue of his liability under an aiding-and-abetting theory. The court concluded that this error was not harmless beyond a reasonable doubt. Consequently, the court reversed Wiggins's convictions and remanded the case for further proceedings consistent with its opinion. View "State of Minnesota vs Wiggins" on Justia Law

In a case before the Supreme Court of Minnesota, the appellant, Thomas Robert Tichich, was found guilty of third-degree criminal sexual conduct and attempted third-degree criminal sexual conduct. Tichich later petitioned for postconviction relief, alleging that two of the State’s expert witnesses falsely testified at his trial and that the jury’s guilty verdicts were legally inconsistent. He submitted a new expert opinion and other evidence to support his claim of false testimony. The district court denied Tichich’s petition, determining that the guilty verdicts were legally consistent and that Tichich’s false-testimony claim failed to satisfy the test set forth in Larrison v. United States.The Supreme Court of Minnesota affirmed the district court's decision, holding that Tichich's claim was one of newly discovered evidence, not one of newly discovered evidence of false testimony, and therefore the standard set forth in Rainer v. State, which governs claims of newly discovered evidence, applied. The court found that Tichich’s claim failed the Rainer test because the new evidence merely served to impeach, rather than disprove, the trial testimony, and would not likely produce a different result given the strength of the State’s evidence.Additionally, the court held that the guilty verdicts for third-degree criminal sexual conduct and attempted third-degree criminal sexual conduct were legally consistent, as no necessary element of one offense negated a necessary element of the other. Therefore, Tichich’s counsel was not ineffective for failing to argue otherwise. View "Tichich vs. State of Minnesota" on Justia Law

The Supreme Court of Minnesota affirmed the conviction of John Ishmael Bradley, III, who was charged with second-degree assault and felony domestic assault for striking his girlfriend over the head with a broom handle. Bradley challenged his convictions, claiming the broom handle was not a dangerous weapon and that his two convictions for one assaultive act was improper.The court ruled that there was sufficient evidence for the jury to conclude that the broom handle was a dangerous weapon. The court determined that an object is "likely to produce death or great bodily harm" if it is used in a manner where death or great bodily harm is a probable or reasonably expected result. Given the manner in which Bradley used the broom handle, the court found there was enough evidence to sustain this claim.The court also examined whether Bradley could be convicted of both second-degree assault and domestic assault for the same criminal act. The court rejected Bradley's argument that domestic assault is a "lesser degree" of second-degree assault. The court concluded that the term "degree" in the phrase "lesser degree of the same crime" in Minnesota Statutes section 609.04, subdivision 1(1), is an unambiguous technical term referring to offenses within an ordinal statutory scheme. Therefore, domestic assault is not a lesser degree of second-degree assault, and the court affirmed both convictions. View "State of Minnesota vs. Bradley" on Justia Law

The case in question involves Dale Edward Lehman, Jr., who was convicted for knowingly permitting a minor to ingest methamphetamine, a violation of Minnesota Statute § 152.137, subd. 2(b) (2022). Lehman appealed, arguing the state failed to provide evidence proving he knew the minor in question, identified as A.D., was under the age of 18. Lehman also argued the court failed to instruct the jury to evaluate whether he knew A.D. was underage. The appellate court affirmed the conviction, stating the statute did not necessitate proof of the defendant's awareness of the minor's age.Lehman's case reached the Supreme Court of Minnesota, where he petitioned for a review. The Supreme Court stated it did not need to resolve the statutory interpretation issue raised by Lehman, as the circumstantial evidence was inconsistent with any rational hypothesis other than Lehman's guilt. The Court took into consideration Lehman's longstanding relationship with the minor's family, his frequent visits to their home, and his statements indicating he knew the minor was underage. The court concluded that the circumstantial evidence was sufficient to show that Lehman knew A.D. was under the age of 18 at the time he provided her with methamphetamine.The Court, therefore, affirmed the decision of the appellate court but on different grounds, maintaining Lehman's conviction. View "State vs. Lehman" on Justia Law