Justia Minnesota Supreme Court Opinion Summaries

Defendant was found guilty of possession of a firearm by an ineligible person. The court of appeals reversed, concluding that the evidence was insufficient to support the conviction. The State petitioned for review, arguing that the court of appeals erred in its application of law and asking the Supreme Court to abandon the separate standard of review for convictions based on circumstantial evidence. The Supreme Court affirmed, holding (1) the court of appeals correctly applied the law and properly found that the State presented insufficient evidence to support Defendant’s conviction; and (2) the State has not established a compelling reason for the court to overrule an approximately century-old rule governing the review of convictions based on circumstantial evidence. View "State v. Harris" on Justia Law

Appellant was convicted of first-degree murder committed for the benefit of a gang. The Supreme Court affirmed. The day before the postconviction statute of limitations expired, Appellant filed his second petition for postconviction relief and, over the next six months, filed various addenda and attachments to his second petition. Appellant also filed a third petition raising additional claims and filed a motion requesting re-testing of certain trial evidence. Without holding an evidentiary hearing, the postconviction court denied both petitions and Appellant’s other requests, determining that his claims were untimely filed or procedurally barred, or failed on the merits. The Supreme Court affirmed, holding that each of the claims Appellant raised in his second and third petitions for postconviction relief, as well as the claims raised in the addenda to the second petition, failed. View "Brown v. State" on Justia Law

Appellant, a juvenile offender, challenged the district court’s imposition of three consecutive sentences of life imprisonment with the possibility of release after thirty years on each sentence for his three murder convictions. Appellant argued, among other things, that the rule announced in Miller v. Alabama and clarified in Montgomery v. Louisiana should apply to his case because his consecutive sentences were, in the aggregate, the functional equivalent of life imprisonment without the possibility of release. The Supreme Court affirmed, holding (1) this court declines to extend the Miller/Montgomery to include Appellant or other similarly situated offenders because the United States Supreme Court has not squarely addressed the issue of whether consecutive sentences should be viewed separately when conducting a proportionality analysis; and (2) Appellant’s three consecutive sentences do no unfairly exaggerate the criminality of his conduct. View "State v. Ali" on Justia Law

The Supreme Court affirmed Defendant’s conviction for first-degree felony murder rendered after a jury trial. The district court sentenced Defendant to life imprisonment with the possibility of release after thirty years. Specifically, the Court held (1) the State presented sufficient evidence to prove beyond a reasonable doubt that the killing of the victim occurred while Defendant was attempting to commit an aggravated robbery; and (2) the district court did not commit plain error by failing to include language requiring a causal relationship between the killing and the attempted robbery in the jury instruction on first-degree felony murder. View "State v. Webster" on Justia Law

In 2015, Appellant was charged with two counts of first-degree driving while impaired (DWI). Appellant contested the use of his 1998 conviction for criminal vehicular operation resulting in substantial bodily harm to enhance his 2015 DWI charge to a first-degree offense. The district court found sufficient probable cause for enhancement. Thereafter, Appellant pleaded guilty to one count of first-degree driving while impaired. Appellant appealed, arguing that he was entitled to withdraw his plea because his 1998 conviction was not included in the list of predicate felonies in Minn. Stat. 169A.24 that enhance a DWI charge to a first-degree DWI. The court of appeals affirmed. The Supreme Court affirmed, holding (1) a criminal vehicular operation conviction from a year not specifically listed in the current version of the first-degree DWI statute can be used to enhance a DWI charge to a first-degree offense; and (2) accordingly, Appellant’s plea was established with an accurate factual basis. View "State v. Boecker" on Justia Law

After a bench trial, Appellant was convicted of three counts of first-degree premeditated murder. The Supreme Court affirmed on direct appeal. Appellant then filed a pro se petition for postconviction relief, arguing that he was entitled to a new trial based on newly discovered evidence in the form of affidavits signed by five alibi witnesses. Appellant also claimed ineffective assistance of trial counsel and appellate counsel. The postconviction court summarily denied Appellant’s motion. The Supreme Court affirmed, holding that the postconviction court did not abuse its discretion by summarily denying Appellant’s request for a new trial based on newly discovered evidence and based on Appellant’s claim that both his trial counsel and appellate counsel provided ineffective assistance. View "State v. Mosley" on Justia Law

A grand jury indicted Appellant for first-degree premeditated murder. After a jury trial, Appellant was found guilty as charged. The district court sentenced Appellant to life imprisonment without the possibility of release. On appeal, Appellant argued that the district court committed reversible error in its pretrial rulings, evidentiary rulings, and instructions to the jury. The Supreme Court affirmed, holding that the district court (1) did not err by denying Appellant’s motion to quash the first-degree murder indictment as untimely; (2) did not abuse its discretion by denying Appellant’s pretrial motion to disclose the entire grand jury transcript; (3) did not err when it excluded evidence of an alternative perpetrator’s prior bad acts; (4) did not commit reversible error in its evidentiary rulings challenged on appeal; and (5) did not commit prejudicial error when it overruled Appellant’s objection to a proposed jury instruction on the law on accomplice liability. View "State v. Guzman" on Justia Law

Defendant was charged with gross misdemeanor second-degree driving while impaired. The matter proceeded to trial. After the State rested, Defendant made a motion for judgment of acquittal, arguing that there was insufficient evidence to convict him of the offense. Thereafter, the State asked to reopen its case-in-chief. The district court granted the State’s motion to reopen and then denied Defendant’s motion for judgment of acquittal. The jury found Defendant guilty as charged. The court of appeals affirmed, concluding that the district court did not err when it granted the State’s motion to reopen its case-in-chief before considering Defendant’s motion for judgment of acquittal. The Supreme Court affirmed, holding that, under the circumstances of this case, the district court did not abuse its discretion when it permitted the State to reopen its case-in-chief in response to Defendant’s motion for judgment of acquittal. View "State v. Thomas" on Justia Law

After a jury trial, Defendant was convicted of first-degree premeditated murder, two counts of attempted first-degree premeditated murder, and three drive-by-shooting counts. Defendant was sentenced to life imprisonment without the possibility of release for the murder conviction. Defendant challenged his convictions by filing a petition for postconviction relief, raising a number of claims. The postconviction court denied the petition in its entirety. The Supreme Court affirmed Defendant’s convictions of first-degree premeditated murder and attempted first-degree premeditated murder but vacated Defendant’s three drive-by-shooting convictions, holding (1) the evidence was sufficient to support the premeditated-murder counts; (2) there was no evidentiary error during trial; (3) the postconviction court did not err when it refused to review the grand-jury transcripts or disclose them to Defendant’s postconviction counsel; but (4) the drive-by-shooting counts were duplicative of the premeditated-murder and attempted-premeditated-murder counts. View "Loving v. State" on Justia Law

After a jury trial, Defendant was found guilty of first-degree premeditated murder and unlawful possession of a firearm. The district court sentenced Defendant to life imprisonment without the possibility of release for the first-degree premeditated murder conviction. This appeal concerned Defendant’s second petition for postconviction relief in which he raised claims alleging newly discovered evidence and ineffective assistance of counsel. The postconviction court summarily denied Defendant’s claims of ineffective assistance of counsel and, after an evidentiary hearing, denied Defendant’s motion for a new trial based on his claim of newly discovered evidence. The Supreme Court affirmed, holding that the postconviction court did not abuse its discretion when it denied Defendant’s request for a new trial based on a claim of newly discovered evidence and when it denied Defendant’s postconviction claims asserting ineffective assistance of counsel. View "Pearson v. State" on Justia Law