Justia Minnesota Supreme Court Opinion Summaries

Appellant was charged with second-degree controlled substance crime, driving after revocation, and possession of drug paraphernalia. Appellant moved to suppress evidence obtained during a search of his vehicle during a traffic stop, asserting that the police illegally expanded the scope and duration of the stop without a reasonable, articulable suspicion. The district court agreed with Appellant, granted his motion to suppress, and dismissed the charges. The court of appeals reversed, concluding that the search was justified by reasonable suspicion. The Supreme Court affirmed, holding that, applying de novo review to the undisputed facts, the district court erred in suppressing the drug evidence discovered as a result of a dog-sniff and the ensuing search because police had a reasonable, articulable suspicion of drug activity that supported the expansion of the vehicle stop. View "State v. Lugo" on Justia Law

Appellant was charged with the issuance of a dishonored check in violation of the dishonored-check statute when her check for past-due property taxes was returned by her bank for insufficient funds. The district court dismissed the criminal complaint, concluding that Appellant’s check for past-due property taxes met the statutory exception for “a check given for a past consideration” because there was no contemporaneous exchange of goods or services for the check. The court of appeals reversed. The Supreme Court reversed, holding (1) “a check given for a past consideration” refers to a check given for a good or service that was received in the past; and (2) because Appellant’s check for past-due property taxes was given, in part, for government services provided in the previous year, her check was “given for a past consideration.” View "State v. Schouweiler" on Justia Law

Defendant pleaded guilty to first-degree sexual conduct. Defendant’s sentence consisted of a term of imprisonment, a supervised-release term, and a conditional-release term. After Defendant was released from prison on supervised release, a hearing officer found that Defendant had violated the terms of his supervised release, revoked his supervised release, and ordered him returned to prison. The Department of Corrections (DOC) later informed Defendant that it had recalculated the projected expiration date of his conditional-release term in light of two recent decisions from the court of appeals. Defendant filed a habeas petition alleging that the DOC’s new method for calculating the expiration date of his conditional-release term was illegal because it did not give him credit for the time he had spent in prison after the DOC had revoked his supervised release. Defendant was subsequently released into the community. Thereafter, the district court denied Defendant’s petition for writ of habeas corpus. The Supreme Court affirmed, holding that an inmate is not entitled to credit against a conditional-release term for any time the inmate spends in prison after the DOC has revoked the inmate’s supervised release. View "State v. Roy" on Justia Law

After a jury trial, Appellant was convicted of first-degree felony murder. Defendant appealed, arguing, among other things, that the district court committed reversible error when it admitted evidence of another crime, wrong, or act - or Spreigl evidence. The Supreme Court affirmed, holding (1) even if the district court erred in admitting the Spreigl evidence, there was no reasonable possibility that the evidence significantly affected the verdict; (2) the district court did not commit reversible error when it denied Appellant’s motion for a mistrial; (3) the State’s evidence was sufficient to prove Appellant shot the victim with an intent to kill; and (4) Appellant’s pro se claims raised in a supplemental pro se brief lacked merit. View "State v. Griffin" on Justia Law

After a jury trial, Defendant was found guilty of possession of a firearm by an ineligible person for possessing a BB gun. The court of appeals affirmed, concluding that an air-powered BB gun is a “firearm” within the meaning of Minn. Stat. 609.165 and that section 609.165 was not unconstitutionally vague as applied to Defendant. The Supreme Court reversed and vacated Defendant’s conviction, holding that an air-powered BB gun is not a “firearm” under the plain meaning of section 609.165, and therefore, Defendant’s possession of an air-powered BB gun did not violate the statute. View "State v. Haywood" on Justia Law

Appellant was convicted of first-degree murder for the benefit of a gang on an accomplice-liability theory. The Supreme Court affirmed. After unsuccessfully filing two postconviction petitions, Appellant filed a third postconviction petition in which he alleged that three witnesses presented false testimony at his trial. Following an evidentiary hearing, the postconviction court denied Appellant’s third postconviction petition. The Supreme Court affirmed, holding (1) the postconviction court did not err when it rejected Appellant’s claim that the prosecutor intimidated a recanting witness when it apprised the witness of his Fifth Amendment rights; and (2) the postconviction court did not err when it struck the testimony the witness gave before invoking his Fifth Amendment privilege. View "Caldwell v. State" on Justia Law

After a jury trial, Defendant was found guilty of first-degree premeditated murder, second-degree intentional murder, and second-degree felony murder. The district court sentenced Defendant, who was eighteen years old at the time he committed the offense, to life in prison without the possibility of release for the first-degree premeditated murder conviction. The Supreme Court affirmed as modified, holding (1) the district court did not err when it denied Defendant’s motion to suppress his confessions because the confessions were voluntary; (2) Defendant forfeited his claim that his mandatory sentence of life imprisonment without the possibility of release violates the Eighth Amendment prohibition on cruel and unusual punishment because he was psychologically and socially a juvenile when he committed the crime; and (3) because the order attached to the Warrant of Commitment incorrectly listed convictions for the two lesser-included offenses, those two convictions are vacated. View "State v. Nelson" on Justia Law

After Defendant was arrested on suspicion of driving while impaired, officers requested that he submit to a warrantless blood or urine test. Defendant agreed to provide a urine sample, but the officer believed that Defendant tampered with the sample and therefore treated his conduct as a refusal. Defendant refused to submit to a blood test. The State charged Defendant with first-degree refusal. Defendant pleaded guilty. Defendant later argued that his guilty plea was not knowing, voluntary, or intelligent because the test refusal statute was unconstitutional as applied. The postconviction court denied relief. The court of appeals affirmed. After deciding State v. Bernard, the Supreme Court reversed the court of appeals’ decision that the test refusal statute was constitutional and remanded for reconsideration. On remand, the court of appeals reversed Defendant’s conviction. The Supreme Court affirmed, holding that Defendant cannot be prosecuted for refusing to submit to an unconstitutional warrantless blood test, and the test refusal statute is unconstitutional as applied. View "State v. Trahan" on Justia Law

After Defendant was arrested on suspicion of driving while impaired, officers asked him to submit to a warrantless blood or urine test. Defendant refused both tests. The State charged Defendant with second-degree test refusal, among other counts. Defendant moved to dismiss the test refusal charge, arguing that the statute was unconstitutional. The district court denied the motion and found Defendant guilty of test refusal. The court of appeals reversed, concluding that charging a defendant with test refusal violates a fundamental right. The Supreme Court affirmed, holding that the test refusal statute is unconstitutional as applied to Defendant. View "State v. Thompson" on Justia Law

After a jury trial, Defendant was convicted of one count of first-degree premeditated murder and two counts of attempted first-degree premeditated murder. The Supreme Court affirmed the convictions on appeal. Defendant later filed a petition for postconviction relief, arguing that appellate counsel was ineffective for failing to raise several issues on appeal. The postconviction court denied the petition without holding an evidentiary hearing. The Supreme Court affirmed, holding that Defendant could not show prejudice from his appellate counsel’s alleged errors, and therefore, the postconviction court did not abuse its discretion by denying Defendant’s postconviction motion without holding an evidentiary hearing. View "Morrow v. State" on Justia Law