Justia Minnesota Supreme Court Opinion Summaries

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

Appellant was convicted of first-degree murder of a peace officer. The Supreme Court affirmed on direct appeal. Appellant subsequently filed a postconviction petition, which the district court denied. The Supreme Court affirmed. Thereafter, Appellant filed a motion for relief from judgment alleging a number of claims, including ineffective assistance of trial and appellate counsel. Treating Appellant’s motion as a second postconviction petition, the district court denied relief, concluding that all of Appellant’s claims were untimely under Minn. Stat. 590.01(4). The Supreme Court affirmed, holding (1) even if the district court had treated Appellant’s request for relief as a motion under Minn. R. Civ. P. 60.02, his request would have been untimely; and (2) Appellant’s claims were also untimely under the postconviction statute. View "Evans v. State" on Justia Law

On July 13, 2007, Appellant was charged with fifth-degree controlled substance crime. Appellant pleaded guilty. On February 27, 2009, the court stayed adjudication of Appellant’s case under Minn. Stat. 152.18(1), placing him on probation. On May 24, 2011, Appellant admitted to violating the terms of his probation. The district court revoked the stay of adjudication and entered a judgment of conviction. On May 23, 2013, Appellant filed a petition for postconviction relief requesting that he be permitted to withdraw his guilty plea. The postconviction court summarily denied the petition on the ground that it was untimely under Minn. Stat. 590.01(4)(a)(1) because it was filed more than two years after the order staying adjudication. The court of appeals affirmed, holding that a stay of adjudication is a “sentence” under Minn. Stat. 590.01(4)(a)(1) that triggers the two-year statute of limitations for filing a postconviction petition. The Supreme Court reversed, holding that a stay of adjudication under Minn. Stat. 152.18(1) is not a judgment of conviction or sentence under Minn. Stat. 590.01(4)(a)(1), and therefore, the district court erred by concluding that Appellant’s petition was time-barred. View "Dupey v. State" on Justia Law

Appellant was found guilty of second-degree murder for the benefit of a gang, attempted second-degree murder, second-degree assault for the benefit of a gang, and second-degree assault. The court of appeals reversed Appellant’s convictions of attempted second-degree murder for the benefit of a gang and second-degree assault for the benefit of a gang. On remand, the district court imposed a 165-month prison sentence for Appellant’s conviction of the lesser-included offense of attempted second-degree murder. On appeal, Appellant argued that because the district court originally imposed a 165-month sentence for his conviction of attempted second-degree murder for the benefit of a gang, the court abused its discretion by imposing the same sentence for his conviction of attempted second-degree murder. The court of appeals affirmed, concluding that the sentence imposed on remand did not violate the public policy and fairness concerns articulated in State v. Prudhomme. The Supreme Court affirmed, holding that Appellant’s sentence was not in error because the record did not support Appellant’s assertion that the district court imposed a greater sentence on remand following his successful appeal of his conviction of attempted second-degree murder for the benefit of a gang. View "State v. Kangbateh" on Justia Law

In 1994, Appellant was convicted of first-degree murder. In 1995, Appellant pleaded guilty to second-degree attempted murder. In 2014, Appellant brought a fifth postconviction petition alleging ineffective assistance of appellate counsel. The postconviction court denied the petition without an evidentiary hearing, concluding that it was both time-barred and procedurally barred. Also in 2014, Appellant brought a second motion to correct his sentence. The postconviction court concluded that the Supreme Court had already decided the issue and denied the motion. The Supreme Court affirmed in both matters, holding (1) Appellant’s postconviction petition was time-barred under Minn. Stat. 590.01(4)(a); and (2) Appellant’s motion to correct his sentence raised the same issue that this Court decided in Appellant's previous petition had no merit, and therefore, the second motion was properly denied. View "Townsend v. State" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder and sentenced to life in prison. The Supreme Court affirmed. Appellant then filed a pro se petition for postconviction relief alleging, inter alia, ineffective assistance of appellate counsel and newly discovered evidence. The postconviction court summarily denied relief on all claims with the exception of the newly discovered evidence claim. After an evidentiary hearing, the postconviction court denied the newly discovered evidence claim. The Supreme Court affirmed, holding that the postconviction court did not abuse its discretion when it (1) summarily denied Appellant’s ineffective assistance of counsel claim because the facts alleged in the petition failed to satisfy the Strickland test; (2) denied Appellant’s newly discovered evidence claim after an evidentiary hearing because the record supported the court’s finding that the testimony of the newly discovered witnesses was doubtful; and (3) summarily denied Appellant’s remaining claims because those claims were procedurally barred. View "Carridine v. State" on Justia Law

In 1987, after a jury trial, Appellant was convicted of first-degree murder and sentenced to life imprisonment. The Supreme Court affirmed. Thereafter, Appellant filed four petitions for postconviction relief and a motion for postconviction DNA testing. All of the petitions or motions were denied. In 2014, Appellant filed his seventh request for relief raising several claims. The postconviction court denied Appellant’s petition without an evidentiary hearing, determining that his claims were time-barred under Minn. Stat. 590.01 and procedurally barred under State v. Knaffla. The Supreme Court affirmed, holding that Appellant’s petition was untimely under Minn. Stat. 590.01(4)(a)(2). View "Wayne v. State" on Justia Law