Justia Minnesota Supreme Court Opinion Summaries

A passenger who grabs the steering wheel of a moving vehicle is “operating” the motor vehicle under the criminal-vehicular-operation statute, Minn. Stat. 609.2113(1).Defendant was charged with criminal vehicular operation after he grabbed the steering wheel of a moving vehicle, causing the vehicle to crash and inflict great bodily harm on the three other occupants of the vehicle. Defendant moved to dismiss the complaint, arguing that he was not “operating” the motor vehicle for purposes of the statute. The district court disagreed, concluding that Defendant had operated the vehicle when he turned the steering wheel. The court of appeals affirmed. The Supreme Court affirmed, holding that the plain meaning of the term “operating” in section 609.2113(1) unambiguously included Defendant’s conduct. View "State v. Henderson" on Justia Law

The Supreme Court affirmed the denial of Appellant’s third petition for postconviction relief, which asserted several claims based on facts alleged in two sworn affidavits, holding that the affidavits were legally insufficient to establish that Appellant was innocent of the offenses of which he was convicted. The postconviction court summarily denied the postconviction petition because it was filed after the statute of limitations in Minn. Stat. 590.01(4)(a) had expired and failed to meet the newly-discovered-evidence exception in Minn. Stat. 590.01(4)(b)(2). The Supreme Court affirmed, holding that the facts were legally insufficient to show that Appellant met the newly-discovered-evidence exception, and therefore, the district court did not abuse its discretion when it summarily denied the petition as untimely filed. View "Henderson v. State" on Justia Law

Past physical abuse, standing alone, can support the issuance of an order for protection (OFP) under the Domestic Abuse Act, Minn. Stat. 518B.01, because the Act imposes no temporal requirement on when the “domestic abuse” occurred.The Supreme Court held that the court of appeals erred when it concluded, as a matter of law, that a finding of past domestic abuse alone is insufficient to support the issuance of an OFP without a showing of a present intent to cause or inflict fear of imminent physical harm. Specifically, the Supreme Court held that, under subdivision 2(a)(1) of the Act, a petition need only show that “physical harm, bodily injury, or assault” has actually occurred, regardless of when it occurred, to satisfy the first definition of “domestic abuse.” View "Thompson v. Schrimsher" on Justia Law

The Supreme Court reversed the postconviction court’s summary denial of Appellant’s pro se petition for postconviction relief, in which Appellant argued that his trial counsel was ineffective and that the prosecutor improperly refused to renew her initial plea offer.Appellant was convicted of first-degree felony murder. After Appellant filed his pro se petition for postconviction relief, Appellant asked the postconviction court to appoint counsel. The postconviction court referred Appellant’s request for counsel to the state public defender, which declined to represent Appellant. The district court then denied Appellant’s postconviction petition without holding an evidentiary hearing. The Supreme Court reversed, holding (1) Appellant was entitled to an appointed attorney for postconviction proceedings because he did not have a “review” on direct appeal; and (2) therefore, the postconviction court erred in not granting Appellant’s request for counsel. View "State v. Eason" on Justia Law

The Supreme Court reversed the postconviction court’s summary denial of Appellant’s pro se petition for postconviction relief, in which Appellant argued that his trial counsel was ineffective and that the prosecutor improperly refused to renew her initial plea offer.Appellant was convicted of first-degree felony murder. After Appellant filed his pro se petition for postconviction relief, Appellant asked the postconviction court to appoint counsel. The postconviction court referred Appellant’s request for counsel to the state public defender, which declined to represent Appellant. The district court then denied Appellant’s postconviction petition without holding an evidentiary hearing. The Supreme Court reversed, holding (1) Appellant was entitled to an appointed attorney for postconviction proceedings because he did not have a “review” on direct appeal; and (2) therefore, the postconviction court erred in not granting Appellant’s request for counsel. View "State v. Eason" on Justia Law

At issue in this case was whether Defendant committed burglary when he entered another guest’s hotel room without that guest’s consent and committed a crime in that room.The Supreme Court affirmed the judgment of the district court finding Defendant guilt of first-degree burglary. On appeal, Defendant argued that the State failed to prove the essential element of burglary that he entered a building without consent. Specifically, Defendant argued that, as a paying guest at the hotel, he had consent to enter the hotel building and, therefore, could not commit burglary while in the hotel. The Supreme Court disagreed, holding that when Defendant entered the victim’s hotel room he exceeded the scope of his consent to be present in the hotel building. Therefore, the evidence was sufficient to sustain Defendant’s conviction. View "State v. Lopez" on Justia Law

At issue in this case was whether Defendant committed burglary when he entered another guest’s hotel room without that guest’s consent and committed a crime in that room.The Supreme Court affirmed the judgment of the district court finding Defendant guilt of first-degree burglary. On appeal, Defendant argued that the State failed to prove the essential element of burglary that he entered a building without consent. Specifically, Defendant argued that, as a paying guest at the hotel, he had consent to enter the hotel building and, therefore, could not commit burglary while in the hotel. The Supreme Court disagreed, holding that when Defendant entered the victim’s hotel room he exceeded the scope of his consent to be present in the hotel building. Therefore, the evidence was sufficient to sustain Defendant’s conviction. View "State v. Lopez" on Justia Law

The Fifth Amendment privilege against self-incrimination does not protect a person from being ordered to prove a fingerprint to unlock a seized cellphone.The police lawfully seized a cellphone from Defendant and attempted to execute a valid warrant to search the cellphone, which had a fingerprint-scanner security lock that prevented the search. When Defendant refused to block the cellphone with his fingerprint the district court ordered Defendant to provide his fingerprint so the police could search the cellphone’s contents. The court of appeals affirmed, concluding that providing a fingerprint was not privileged under the Fifth Amendment. The Supreme Court affirmed, holding that because providing the fingerprint elicited only physical evidence from Defendant and did not reveal the contents of his mind, no violation of the Fifth Amendment privilege against self-incrimination occurred. View "State v. Diamond" on Justia Law

The Supreme Court affirmed Defendant’s conviction for first-degree premeditated murder, holding that there was no abuse of discretion.On appeal, Defendant argued that the district court abused its discretion when it (1) declined to excuse a juror who, after the trial began, realized that she knew a witness and had been exposed to news coverage of the shooting; and (2) improperly excluded reverse-Spreigl alternative-perpetrator evidence. The Supreme Court disagreed, holding (1) the district court did not abuse its discretion in declining to remove the juror at issue from the jury; and (2) the district court did not abuse its discretion by excluding the reverse-Spreigl evidence. View "State v. Curtis" on Justia Law

Appellant Emile Rey pleaded guilty to one count of identity theft involving eight or more direct victims. The district court ordered Rey to pay the mandatory-minimum restitution of $1,000 to each of his 66 direct victims, totaling $66,000. Rey appealed, asserting that the mandatory-minimum restitution he was ordered to pay violated his procedural and substantive due process rights and was an unconstitutional fine. The court of appeals affirmed. Rey asked the Minnesota Supreme Court to declare the statute unconstitutional, vacate the restitution order, and remand the matter for a restitution hearing or a Blakely trial. The Court declined, and affirmed the restitution order. View "Minnesota v. Rey" on Justia Law