Justia Minnesota Supreme Court Opinion Summaries

In 2005, Appellant pleaded guilty to second-degree burglary, a felony. When Appellant was released from probation the conviction was deemed a misdemeanor. In 2015, Appellant filed a petition for expungement. The district court denied the petition, concluding that Appellant was not “convicted of” a misdemeanor and therefore could not petition for expungement under Minn. Stat. 609A.02, subd. 3(a)(3). The court of appeals affirmed. The Supreme Court affirmed, holding that felony convictions later deemed misdemeanors by operation of law under Minn. Stat. 609.13, subd. 1(2) are not eligible for expungement under Minn. Stat. 609A.02, subd. 3(a)(3). View "State v. S.A.M." on Justia Law

The State charged Defendant under Minn. Stat. 609.352, subd. 2a(2) with felony communication with a child describing sexual conduct after she sent sexually explicit images and messages to a fifteen-year-old boy. Defendant filed a motion to dismiss, arguing that section 609.352, subd. 2a(2) proscribes a substantial amount of speech that the First Amendment protects and thus facially violates the First Amendment. The district court concluded that the statute violates the First Amendment, and the court of appeals affirmed. The Supreme Court reversed, holding that 609.352, subd. 2a(2) is not substantially overbroad in relation to its plainly legitimate sweep. View "State v. Muccio" on Justia Law

After Appellant pleaded guilty to third-degree criminal sexual conduct, removal proceedings were initiated against him. In an attempt to avoid deportation, Appellant filed an emergency motion to withdraw his guilty plea, arguing, inter alia, that he received ineffective assistance of counsel because counsel failed accurately to inform him that his plea would lead to his removal from the United States. Specifically, Appellant argued that Padilla v. Kentucky required his attorney to advise him that the plea would result in his deportation, rather than just the deportation was a possibility. The postconviction court denied Appellant’s motion. The court of appeals affirmed. The Supreme Court affirmed, holding that Padilla did not require Appellant’s counsel to do anything more than provide a general warning about the immigration consequences of entering the plea, and therefore, Appellant’s counsel satisfied his obligation under the Sixth Amendment. View "Sanchez v. State" on Justia Law

Defendant was arrested and charged with drug-related crimes. The district court ordered Defendant’s pretrial release. The district court later found probable cause that Defendant had violated the conditions of her release and issued a warrant for her arrest. Officers then went to the residence of Defendant’s boyfriend. One officer opened an unlocked door, went inside, and arrested Defendant. While arresting her, the officer saw marijuana and a bong in plain view. Law enforcement then obtained a search warrant for the apartment of Defendant’s boyfriend. The state subsequently charged Defendant with two counts of fifth-degree possession of a controlled substance and possession of drug paraphernalia. The district court suppressed all fruits of Defendant’s arrest and dismissed the charges, concluding that the arrest was illegal because the warrant for Defendant's arrest did not authorize police to enter her boyfriend’s apartment. The court of appeals reversed. The Supreme Court affirmed, holding that neither the Fourth Amendment of the U.S. Constitution nor Article I, Section 10 of the Minnesota Constitution requires police to obtain a search warrant before entering a home to arrest a guest who is the subject of a lawfully issued arrest warrant. View "State v. deLottinville" on Justia Law

After the Supreme Court overturned Petitioner’s first conviction on direct appeal, Petitioner was tried a second time and convicted of first-degree murder while committing or attempting to commit a kidnapping. Petitioner was sentenced to life in prison without the possibility of release. The Supreme Court affirmed. This appeal concerned Petitioner’s third petition for postconviction relief in which Petitioner raised a variety of claims. The postconviction court summarily denied the claims as either meritless or untimely filed. The Supreme Court affirmed, holding that the postconviction court did not abuse its discretion in summarily denying the petition, as one of Petitioner’s claims was meritless and the remaining claims were untimely filed. View "Hannon v. State" on Justia Law

Defendant was convicted of first-degree premeditated murder and sentenced to life in prison without the possibility of release. The court concluded that the district court did not commit plain error in admitting evidence of defendant's post-arrest, pre-Miranda silence during the State's case-in-chief; any error by the district court in permitting the State to discuss defendant's post-arrest, pre-Miranda silence in closing argument was harmless; and the district court did not abuse its discretion in denying defendant's request to give a jury instruction on defense of dwelling. Accordingly, the court affirmed the judgment. View "State of Minnesota v. Lilienthal" on Justia Law

Defendant was convicted of a petty misdemeanor for violating Lester Prairie Municipal Code section 5.5.1.2, which prohibits certain blight conditions on residents’ property, including the open storage of unregistered or inoperative motor vehicles. The court of appeals reversed, concluding that the ordinance was ambiguous and resolving the ambiguity in favor of Defendant. The Supreme Court reversed, holding (1) the unambiguous language of the ordinance prohibits a person from keeping a junked or abandoned vehicle or other scrap metal on her property for longer than thirty days without a special use permit; and (2) there was sufficient evidence to prove that Defendant violated the ordinance by keeping an abandoned vehicle on her property for longer than thirty days without a special use permit. View "State v. Vasko" on Justia Law

John David Emerson was arrested and charged with second-degree assault with a dangerous weapon. Upon Emerson’s motion, the district court issued an order restraining the Dakota County Sheriff from collecting Emerson’s DNA for law enforcement identification purposes. The Sheriff filed a petition for a writ of prohibition asking the court of appeals to prohibit the district court from enforcing its order against the Sheriff, arguing that the district court lacked subject matter jurisdiction to hear and decide Emerson’s motion. The court of appeals denied the motion. The Supreme Court reversed, holding (1) the district court had subject matter jurisdiction but exceeded its lawful authority when it used the wrong procedure to address Emerson’s constitutional challenge the DNA-collection statute; and (2) the Sheriff met all three elements for a writ of prohibition. View "In re Leslie, Dakota County Sheriff" on Justia Law

After a jury trial, Appellant was found guilty of first-degree murder, first-degree attempted murder, and other crimes. The district court sentenced Appellant to consecutive terms of life imprisonment without the possibility of release for the murder and attempted murder convictions. The Supreme Court affirmed the convictions, holding that the district court did not err when it (1) excluded evidence that Defendant claimed was relevant to an element of his self-defense claim; (2) denied Defendant’s request for a third-degree murder instruction; and (3) denied Defendant’s pretrial motion to dismiss the first-degree murder charge. View "State v. Zumberge" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder while committing a felony involving the unlawful sale of a controlled substance. The district court sentenced Appellant to life imprisonment with the possibility of release after serving a minimum of thirty years in prison. The Supreme Court affirmed Appellant’s conviction on direct appeal. This appeal concerned Appellant’s second petition for postconviction relief, in which he argued that there was insufficient evidence to support his conviction. The postconviction court summarily denied Appellant’s petition. The Supreme Court affirmed, holding that the postconviction court did not abuse its discretion in denying Appellant’s postconviction petition without holding an evidentiary hearing. View "Gail v. State" on Justia Law