Justia Minnesota Supreme Court Opinion Summaries

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

After a jury trial, Appellant was convicted of felony fourth-degree assault of a peace officer in violation of Minn. Stat. 609.2231(1). Appellant appealed, arguing that the district court abused its discretion by declining to instruct the jury that the act of intentionally throwing or otherwise transferring bodily fluids at or onto an officer, in itself, is a physical assault only when the defendant inflicted or attempted to inflict bodily harm on the officer. The court of appeals affirmed, concluding that the transfer of bodily fluids onto an officer in itself constitutes fourth-degree felony assault. The Supreme Court reversed, holding (1) the unambiguous language of section 609.2231(1) requires that the State prove the elements of a physical assault in addition to proving that a defendant intentionally threw or transferred bodily fluids at or onto the officer; and (2) the district court in this case erred by omitting the element of “physical assault” in its instructions to the jury. View "State v. Struzyk" on Justia Law

Defendant was the driver of a vehicle that was involved in a single-vehicle rollover crash. The accident resulted in one fatality. At the time of the accident, an officer obtained a blood draw from Defendant, and later testing of that blood revealed an alcohol concentration of 0.20. The State charged Defendant with three counts of criminal vehicular operation resulting in death, two counts of fourth-degree driving while impaired, reckless driving, and careless driving. Defendant filed a motion to suppress the alcohol concentration test results on the grounds that his blood was drawn without a warrant and without his consent. The district court suppressed the alcohol concentration test results, concluding that the State failed to satisfy the exigent circumstances exception as applied in Missouri v. McNeely. The court of appeals reversed, concluding that the State established that exigent circumstances justified the warrantless blood draw. The Supreme Court affirmed, holding that the State proved the existence of exigent circumstances justifying the warrantless blood draw. View "State v. Stavish" on Justia Law

Appellant was convicted of third-degree driving while impaired. At trial, the court admitted test results showing Appellant’s alcohol concentration at the time of the incident that were based on a warrantless blood draw. After the court of appeals affirmed the conviction, the Supreme Court decided Missouri v. McNeely, which held that the dissipation of alcohol in the blood does not create a single-factor exigency justifying a warrantless blood draw of suspected drunk drivers. Defendant petitioned for review to determine whether, in light of McNeely, her blood draw was an unconstitutional search. The Supreme Court vacated the court of appeals’ decision and remanded for further proceedings in light of McNeely. On remand, the court of appeals again affirmed. The Supreme Court affirmed, holding (1) McNeely applies to cases on direct review at the time of decision; but (2) the test results from Appellant’s blood draw, even if obtained in violation of Appellant’s constitutional rights, need not be suppressed because the officer who facilitated the blood draw acted in objectively reasonable reliance on binding appellate precedent. View "State v. Lindquist" on Justia Law

After a jury trial in 1995, Appellant was found guilty of first-degree premeditated murder and attempted first-degree premeditated murder. The district court imposed a sentence of life imprisonment with the possibility of release for the first-degree murder offense and a consecutive sentence of 180 months’ imprisonment for the attempted first-degree murder offense. In 2014, Appellant, who is African American, moved to correct his sentence, arguing that his sentence was unlawful under Minn. Sent. Guidelines II.F and that his sentence violated his right to equal protection because his sentence was more severe than the sentences of other similarly situated offenders who were not African American. The postconviction court denied relief. The Supreme Court affirmed, holding that the postconviction court did not abuse its discretion by denying Appellant’s motion to correct his sentence. View "Nunn v. State" on Justia Law