Justia Minnesota Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of first-degree premeditated murder on an accomplice-liability theory. The district court sentenced Defendant to life imprisonment without the possibility of release. The Supreme Court affirmed, holding (1) the district court did not err in denying Defendant’s motion to suppress evidence seized as a result of her arrest, as the arrest was supported by probable cause; (2) the district court did not err in overruling Defendant’s challenges to the State’s peremptory strikes of certain jurors under Batson v. Kentucky; (3) the district court did not abuse its discretion when instructing the jury on accomplice liability; and (4) Defendant’s pro se contentions lacked merit. View "State v. Onyelobi" on Justia Law

After a jury trial, Defendant was convicted of first-degree premeditated murder and sentenced to life imprisonment without the possibility of release. The Supreme Court affirmed the conviction, holding (1) the district court did not err when it denied Defendant’s motion to suppress statements from a police interview conducted shortly after the murder; (2) the warrantless seizure of Defendant’s cellphone did not violate her constitutional rights; (3) Defendant was not entitled to relief on her claim that defective search warrants violated her constitutional rights; (4) the district court did not err when it failed to give an accomplice-corroboration jury instruction; (5) the district court did not err in denying Defendant’s request to remove a juror for cause; and (6) the evidence was sufficient to support Defendant’s conviction of first-degree premeditated murder. View "State v. Horst" on Justia Law

Defendant entered a straight plea to the charge of conspiracy to commit a first-degree controlled substance crime. At the plea hearing, Defendant waived his right under Blakely v. Washington to have a jury determine whether aggravating factors existed to justify an upward durational department to his sentence. During Defendant’s Blakely court trial to determine whether the alleged aggravating factors existed, the district court did not apply the Minnesota Rules of Evidence. After the trial, the district court concluded that the State proved all three of the aggravating sentencing factors. The court imposed a 240-month sentence, a greater than double upward durational departure from the presumptive sentencing range. The court of appeals affirmed, concluding that the rules of evidence do not apply during a Blakely court trial. The Supreme Court affirmed as modified, holding that the rules of evidence apply in a Blakely court trial, but there was no objection and the error was not plain. View "State v. Sanchez-Sanchez" on Justia Law

Respondent was pulled over by a police office on suspicion of driving while impaired for taking a wide right turn and weaving once within his lane around 2 a.m. Respondent was arrested and subsequently charged with second degree driving while impaired. Respondent moved to dismiss the charges, arguing that the arresting officer lacked a valid basis for the traffic stop. The trial court denied the motion to dismiss. Respondent was subsequently found guilty of one count of second-degree driving while impaired-alcohol concentration of 0.08 or more within two hours. The court of appeals reversed, concluding that the stop was improper. The Supreme Court reversed, holding that, under the totality of the circumstances, the arresting officer had a reasonable, articulable suspicion to justify the vehicle stop. View "State v. Morse" on Justia Law

Pursuant to a plea agreement, Appellant pleaded guilty to aiding and abetting first-degree murder and second-degree intentional murder. One year later, Appellant petitioned for postconviction relief under Minn. Stat. 590.01. The postconviction court denied relief. Defendant later filed a motion to correct his sentence pursuant to Minn. R. Crim. P. 27.03(9) challenging the validity of his guilty plea. The postconviction court denied relief on all of Appellant’s claims with the exception of a clerical error, concluding that Appellant’s claims were properly treated as requests for postconviction relief under Minn. Stat. 590.01 and that the holding in State v. Knaffla barred Appellant’s claims. Five years later, Appellant filed a motion to correct his sentence under Minn. R. Crim. P. 27.03(9). The postconviction court denied relief, concluding that Appellant motion was, in effect, a petition for postconviction relief and that it was both untimely and Knaffla-barred. The Supreme Court affirmed, holding that the postconviction court properly dismissed Appellant’s claim as untimely. View "Johnson v. State" on Justia Law

After a jury trial, Defendant was found guilty of second-degree intentional murder and second-degree felony murder. Defendant was sentenced to 306 months in prison for second-degree intentional murder. Defendant appealed, arguing that the accomplice-liability instructions given to the jury failed accurately to state the law. The court of appeals affirmed, concluding that the accomplice-liability instructions were plainly erroneous but that the error did not affect Defendant’s substantial rights. The Supreme Court reversed, holding (1) the instructions at issue were plainly erroneous; (2) Defendant met his burden of proving that the plainly erroneous jury instructions affected his substantial rights; and (3) a new trial was necessary in this case to protect the fairness, integrity, and public reputation of the judicial proceedings. View "State v. Huber" on Justia Law

After a jury trial, Appellant was found guilty of two counts of first-degree murder and two counts of second-degree murder. The district court sentenced Appellant to life imprisonment without the possibility of release on the first-degree murder conviction. The Supreme Court affirmed on appeal. After unsuccessfully seeking postconviction relief, Appellant filed a second petition for postconviction relief, alleging that he was entitled to a new trial on two grounds. The postconviction court denied the petition without holding an evidentiary hearing. The Supreme Court affirmed, holding (1) Appellant’s claim that the district court gave an erroneous jury instruction during trial was untimely, and the postconviction court did not abuse its discretion when it denied his petition without a hearing; and (2) Appellant was not entitled to relief in the interests of justice based on any of the issues he raised. View "Bolstad v. State" on Justia Law

After a jury trial, Appellant was found guilty of first-degree premeditated murder. The Supreme Court affirmed the conviction on appeal. Appellant subsequently filed a pro se petition for postconvction relief raising several legal claims without providing factual support for any of them. Appellant separately moved for additional time to file an addendum that would set forth the necessary factual support for his petition. Appellant then moved to disqualify the postconviction judge assigned to his postconviction proceeding. The postconviction judge denied both Appellant’s motion to disqualify and the motion for additional time to file an addendum. Thereafter, the postconviction court denied Appellant’s petition for postconviction relief, ruling that most of Appellant’s claims could have been raised on direct appeal. The Supreme Court affirmed, holding (1) the postconviction judge erred by failing to refer to the Chief Judge of the Tenth Judicial District Appellant’s motion to disqualify, but the error was harmless; and (2) the postconviction court did not abuse its discretion by denying Appellant’s petition for postconviction relief and motion for additional time to file an addendum. View "Rossberg v. State" on Justia Law

After a bench trial, Defendant was convicted of third-degree possession of a controlled substance. Defendant appealed, arguing that the district court erred by denying his motion to suppress the heroin seized from the car he was driving on the grounds that the police unlawfully searched the car without a warrant. The court of appeals reversed, concluding that the police did not have probable cause to arrest Defendant or to search his car. The Supreme Court reversed, holding that the warrantless search of Defendant’s car was lawful under the automobile exception because there was probable cause to believe that Defendant’s car contained contraband, and therefore, the district court properly denied Defendant’s motion to suppress. View "State v. Lester" on Justia Law

After a jury trial, Appellant was found guilty of first-degree murder while committing child abuse, second-degree felony murder, and second-degree manslaughter. The district court imposed a life sentence with eligibility for supervised release after thirty years. The Supreme Court affirmed the conviction, holding (1) the jury instruction describing felony malicious punishment of a child as a type of child abuse was plainly erroneous, but Appellant failed to establish that the erroneous jury instruction affected her substantial rights; (2) assuming that the district court abused its discretion when it allowed a state expert to testify that biting a child is a “particularly vicious” form of child abuse, there was no reasonable likelihood that the testimony significantly affected the verdict in this case; and (3) the prosecutor made improper remarks during closing argument, but the prosecutorial misconduct did not affect Appellant’s substantial rights. View "State v. Peltier" on Justia Law