Justia Minnesota Supreme Court Opinion Summaries

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

Prior to his scheduled probation revocation hearing, Probationer moved the district court judge for disqualification or, in the alternative, to direct the chief judge of the district to determine whether the district court judge was disqualified due to what Probationer alleged was a “reasonable question” about judicial impartiality. The district court rejected Probationer’s motions in their entirety without issuing a written order and, after a probation revocation hearing, revoked Probationer’s probation and executed his sentence. On appeal, Probationer argued that Minn. R. Crim. P. 26.03(14)(3) requires the chief judge of the district court to hear requests to disqualify. The court of appeals affirmed, concluding that Probationer’s arguments failed both procedurally and on the merits. The Supreme Court reversed the decision of the court of appeals and vacated the probation revocation order, holding (1) Probationer’s appeal was not procedurally flawed; and (2) the district court erred when it declined to refer the request to disqualify to the chief judge of the district, and the error was not harmless. View "State v. Finch" on Justia Law

Pursuant to a plea agreement, Defendant pleaded guilty to terroristic threats. The victim filed a request for restitution, including the cost of hiring an employee to help the victim perform his job while his injuries healed. The district court concluded that the language of Minn. Stat. 611A.045(1) does not prohibit consideration of the victim’s fault and thus awarded the victim only half of the employment-related expenses that he sought because the victim was the initial aggressor. The court of appeals reversed and remanded with instructions to the district court to consider only the factors identified in section 611A.045(1) when determining the amount of restitution. The Supreme Court affirmed, holding that a victim’s role as an initial aggressor may not be considered when determining the amount of restitution to award for economic loss sustained by the victim as a result of the offense. View "State v. Riggs" on Justia Law

After a jury trial, Appellant was convicted of two counts of first-degree murder. The Supreme Court affirmed the conviction, holding that the district court (1) did not err in admitting evidence from Appellant’s cell phone because the police lawfully seized the cell phone under the plain-view exception to the warrant requirement; (2) did not err in admitting evidence obtained from the execution of numerous search warrants because the search warrants were supported by probable cause; and (3) did not abuse its discretion in dismissing a juror for cause. View "State v. Holland" on Justia Law

After a jury trial, Respondent was convicted of unintentional second-degree murder. During trial the State sought to introduce evidence, through the admission of evidence of Respondent’s prior bad acts, that Respondent had a pattern of shifting blame and falsely asserting self-defense after being the aggressor in an altercation. Respondent appealed, claiming that the admission of evidence relating to three previous assaults constituted impermissible character evidence. The court of appeals reversed and remanded for a new trial, concluding that the evidence did not tend to disprove the elements of self-defense and therefore unfairly prejudiced the defense. The Supreme Court reversed, holding (1) evidence of Respondent’s pattern of shifting blame and falsely asserting self-defense was relevant to one or more of the elements of Defendant’s self-defense claim; and (2) the trial court did not commit reversible error when it admitted the previous incidents of assault. View "State v. Welle" on Justia Law