Justia Minnesota Supreme Court Opinion Summaries

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

The Supreme Court of Minnesota reviewed a case in which Robert John Kaiser had been convicted of second-degree felony murder for the death of his infant son. Kaiser sought postconviction relief, arguing that two expert witnesses for the State had presented false evidence at his trial. The district court granted a new trial, determining that the expert testimony at issue was indeed false and that the jury might have reached a different conclusion without it. The State appealed this decision, arguing that the district court abused its discretion in ordering a new trial.The Supreme Court of Minnesota upheld the lower court's decision, stating that the district court had not abused its discretion. It held that the Larrison test, which is used to determine the legitimacy of claims of witness recantation or false trial testimony, was the appropriate legal standard for this case. The court found that the expert testimony presented at Kaiser's trial was factual and false, thus meeting the requirements of the Larrison test. The court further found that the jury might have returned a different verdict without the false testimony. Therefore, the Supreme Court of Minnesota affirmed the decision of the lower courts to grant Kaiser a new trial. View "Kaiser vs. State" on Justia Law

In Minnesota, a defendant, Rebecca Julie Malecha, was arrested on a warrant that had been quashed but was still appearing as active in law enforcement databases due to a clerical error by court administration. During the arrest, police discovered controlled substances on Malecha's person and charged her with four controlled substance crimes. Malecha moved to dismiss the charges, arguing the search was unconstitutional due to the quashed warrant. The district court granted her motion, based on the violation of Article I, Section 10, of the Minnesota Constitution, but the court of appeals reversed this decision.The Minnesota Supreme Court reversed the court of appeals, holding that the good-faith exception to the exclusionary rule does not apply to evidence obtained during a search on a quashed warrant that appears active to law enforcement because of a clerical error by court administration. The court reasoned that applying the exclusionary rule would serve to deter unlawful government conduct generally, not just police misconduct. The court emphasized that the benefits of excluding illegally obtained evidence outweighed the costs in this case, particularly in situations where the constitutional violation stemmed from a court clerical error. Therefore, the charges against Malecha were dismissed. View "State of Minnesota vs. Malecha" on Justia Law

The State of Minnesota Supreme Court affirmed the decision of the Court of Appeals that the District Court did not abuse its discretion when it ordered an upward durational sentencing departure for third-degree criminal sexual conduct against a physically helpless person, in violation of Minnesota Statutes section 609.344, subdivision 1(d) (2020), when the offense occurred in the victim’s zone of privacy.The appellant, Curtis Lablanche Vanengen, was found guilty by the jury of third-degree criminal sexual conduct against a physically helpless person. The offense took place in the victim’s bedroom, which the jury determined as the victim’s zone of privacy. The district court sentenced Vanengen to 120 months in prison, a 29-month upward durational departure from the top of the presumptive sentencing guidelines range.Vanengen appealed, arguing that the location of the offense in the victim’s bedroom did not make it “significantly more serious” than the “typical” criminal sexual conduct offense against a physically helpless person who is asleep. The court of appeals and the Supreme Court disagreed, stating that the victim was entitled to safety and security in her own home, and the violation of this security by committing the offense in her private zone justified the upward departure. The Supreme Court concluded that the zone-of-privacy aggravating factor was a legally permissible reason for an upward departure in this type of case and was factually supported in the record. The court affirmed the decision of the court of appeals. View "State of Minnesota vs. Vanengen" on Justia Law