Justia Minnesota Supreme Court Opinion Summaries

After a jury trial, Appellant was convicted of first-degree murder. The Supreme Court affirmed. Appellant later filed his current petition for postconviction relief alleging that a witness had recanted his trial testimony. After an evidentiary hearing to determine the credibility of the alleged recantation, the postconviction court denied the petition, concluding that “it was not well satisfied that the trial witness’s testimony was false.” The Supreme Court affirmed, holding (1) Appellant failed to prove that the State substantially interfered with the decisions of Appellant’s witnesses about whether to testify at the postconviction hearing; and (2) the postconviction court did not abuse its discretion by refusing to grant use immunity to Appellant’s witnesses or by finding that Appellant presented insufficient evidence to warrant a new trial. View "McKenzie v. State" on Justia Law

In 2008, Appellant was convicted of first-degree premeditated murder. The district court sentenced Appellant to life imprisonment and reserved the issue of restitution for thirty days. The court, however, took no further action on the restitution issue until 2014, when the court granted the restitution request and ordered Appellant to pay $6,500 in restitution. Appellant filed a motion to stop the restitution payments and return the funds taken. The district court denied the motion, concluding that Appellant had properly been served with the restitution request and had failed to timely object to it. The Supreme Court affirmed as modified, holding (1) the district court had the statutory authority to order restitution and did not abuse its discretion in ordering Appellant to pay $6,500 in restitution; and (2) the court properly denied Appellant’s motion to return the funds taken, as the motion was not properly before the district court. View "State v. Anderson" on Justia Law

The State charged Appellant with aiding and abetting first-degree sale of a mixture of a controlled substance of ten grams or more in connection with the sale of methamphetamine. During trial, Appellant objected to the admission of test results by the Minnesota Bureau of Criminal Apprehension (BCA) that confirmed the substance was methamphetamine, arguing that the BCA results were unreliable because the contents of the bags might have been contaminated while the bags were in the custody of the St. Paul Police Crime Lab, which had been investigated for deficiencies in its quality-assurance controls. The district court rejected Appellant’s contamination argument, and Appellant was subsequently convicted of the charged offense. The court of appeals affirmed. Before the Supreme Court, Appellant asked that the Court adopt a new standard that would presume that all evidence processed through the Crime Lab is contaminated and inadmissible unless the State can prove the absence of contamination. The Supreme Court affirmed, holding that the invocation of the Court’s supervisory powers to adopt Respondent’s requested presumption of contamination is not required to ensure the fair administration of justice, and constitutional principles do not require the rebuttable presumption Appellant proposed. View "State v. Hill" on Justia Law

As a condition of his probation from a prior conviction, Respondent was required to attend anger-management therapy sessions with N.M., a mental-health practitioner. During one session, Respondent made a threatening statement about a caseworker assigned to a child-protection case involving Respondent’s children. N.M. determined that Respondent’s statements triggered her statutory duty to warn and reported the statements to the police. The State charged Respondent with one count of making terroristic threats. The jury found Respondent guilty. Respondent appealed, asserting that N.M.’s testimony was inadmissible under the therapist-client privilege. The court of appeals reversed, concluding (1) the therapist-client privilege is not subject to a “threats exception”; and (2) Respondent’s privileged statements were inadmissible through the testimony of any witness, including D.P. The Supreme Court affirmed as modified, holding (1) the statute does not contain a threats exception; (2) the privilege does not apply to the testimony of third parties who learn of confidential information shared by a client with his or her therapist; and (3) Respondent was entitled to a new trial due to N.M.’s disclosure of privileged information at trial. View "State v. Expose" on Justia Law

After a jury trial in 2003, Appellant was found guilty of first degree murder and sentenced to life imprisonment without the possibility of release. In 2014, Appellant filed his sixth postconviction petition, alleging newly discovered evidence, juror misconduct, and that cumulative errors required a new trial in the interests of justice. The postconviction court denied Appellant’s petition without holding an evidentiary hearing. The Supreme Court affirmed, holding that the postconviction court did not abuse its discretion in denying the petition, as the record conclusively showed that Appellant’s claims were either harmless beyond a reasonable doubt, procedurally barred, or meritless. View "Colbert v. State" on Justia Law

In 1987, after a jury trial, Appellant was convicted of first-degree murder while committing criminal sexual conduct. Appellant was sentenced to life in prison. In 2014, Appellant brought a motion to correct his sentence. The postconviction court treated Appellant’s motion as a petition for postconviction relief and denied it because of Appellant’s failure to file it until after the two-year postconviction statute of limitations had expired. The Supreme Court affirmed, holding that the postconviction court did not abuse its discretion when it denied relief to Appellant on the grounds that the statute of limitations had expired. View "Wayne v. State" on Justia Law

After a jury trial, Defendant was found guilty of first-degree assault. The jury found that certain facts existed to support a sentencing departure under the repeat offender aggravating factor. After a sentencing hearing, the district court departed upward from the presumptive sentence range of 135-189 months and sentenced Defendant to the statutory maximum sentence of 240 months. The court of appeals affirmed the sentence, concluding that the repeat offender aggravating factor provided a valid ground for departure and that the district court did not abuse its discretion by imposing a 240-month sentence. The Supreme Court affirmed, holding (1) the district court properly applied the repeat offender aggravating factor to Defendant’s first-degree assault conviction; and (2) the district court did not abuse its discretion in imposing a 240-month sentence. View "State v. Meyers" on Justia Law

In 1997, Appellant was convicted of first-degree premeditated murder and attempted first-degree murder. In 2003, Appellant filed his first postconviction petition. The postconviction court denied the petition after holding an evidentiary hearing. In 2013, Appellant filed his second postconviction petition, claiming that he received ineffective assistance of trial and appellate counsel. The postconviction court denied the petition without holding an evidentiary hearing, concluding that the petition was both untimely under the two-year statute of limitations for filing a postconviction petition and procedurally barred under State v. Knaffla. The Supreme Court affirmed, holding that Appellant’s claims were procedurally barred. View "Williams v. State" on Justia Law

After being placed on probation, Appellant was cited for consumption of alcohol by a minor and disorderly conduct. The State subsequently moved to have Appellant’s probation revoked, and the State cited Appellant for misdemeanor contempt of court. Appellant moved to dismiss the criminal contempt charge. The district court granted the motion, concluding that the statute charged does not cover violations of probationary terms. Meanwhile, Appellant’s probation was revoked, and the sentence was executed. The Supreme Court affirmed the dismissal of the contempt charge after determining and clarifying the relationship between both the contempt and probation statutes, holding that a willful violation of of a “term” of probation prescribed at sentencing does not itself constitute the crime of violation of a “mandate of a court” under the criminal contempt statute. View "State v. Jones" on Justia Law

After a jury trial, Defendant was convicted of one count of first-degree murder and two counts of attempted first-degree murder. The Supreme Court affirmed the convictions, holding (1) the district court’s exclusion from the courtroom members of the public that did not have photographic identification did not constitute a partial courtroom closure; (2) even if the district court’s exclusion of certain evidence supporting an alternative motive of accomplice witnesses was erroneous, the error was harmless; (3) even if the district court erred in admitting testimony from a gang expert identifying Defendant as a gang member, the error was harmless; (4) the district court did not plainly err in instructing the jury on aiding and abetting liability; (5) the district court did not plainly err by not giving a limiting instruction sua sponte regarding Appellant’s prior convictions; (6) the district court did not violate Defendant’s right to a speedy trial; (7) the district court did not err in admitting into evidence a handwritten note seized from Defendant’s jail cell; (8) Defendant waived review of whether the admission into evidence of prison phone call recordings was erroneous; and (9) the cumulative effect of the two assumed errors did not deprive Defendant of a fair trial. View "State v. Taylor" on Justia Law