Justia Minnesota Supreme Court Opinion Summaries

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

After a jury trial, Defendant was convicted of third-degree criminal sexual conduct for sexually penetrating a member of the parish where he served as a priest. The court of appeals reversed and ordered a new trial, holding that the district court erred in (1) failing to provide a specific-unanimity instruction; (2) failing to instruct the jury that State was required to prove that Defendant had subjective knowledge of the purpose of the meeting at which sexual penetration occurred; and (3) denying Defendant’s motion to admit evidence of the complainant’s sexual history after it admitted the State’s evidence of the victim’s sexual inexperience. The Supreme Court reversed, holding (1) the district court’s failure to provide a specific-unanimity jury instruction did not affect Defendant’s substantial rights; (2) the clergy sexual conduct statute does not require the clergy member to know that the complainant seeks or is receiving spiritual counsel; and (3) even assuming the district court abused its discretion in disallowing Defendant’s sexual-history evidence, any error was harmless beyond a reasonable doubt. View "State v. Wenthe" on Justia Law

After a jury trial, Appellant was found guilty of first-degree murder committed for the benefit of a gang and first-degree premeditated murder. Appellant was convicted of first-degree premeditated murder, and the district court imposed a sentence of life without the possibility of release. The Supreme Court affirmed. Appellant later filed a petition for postconviction relief, alleging, inter alia, newly discovered evidence of the recantations of two witnesses. The Supreme Court remanded the case to the postconviction court for an evidentiary hearing on the witness recantation claim. Thereafter, Appellant filed a second petition for postconviction relief, alleging that his sentence was unconstitutional and that he was entitled to retroactive application of Miller v. Alabama. The postconviction court consolidated both matters, conducted an evidentiary hearing, and (1) denied Appellant’s witness recantation claim from his first postconviction petition, and (2) denied Appellant’s second postconviction petition. The Supreme Court affirmed, holding (1) Appellant was not entitled to a new trial on his witness recantation claim; and (2) Appellant’s second petition for postconviction relief was time-barred. View "Martin v. State" on Justia Law

After a jury trial, Appellant was convicted of unlawful possession of a firearm and first-degree felony murder. The district court sentenced Appellant to life in prison with the possibility of release. The Supreme Court affirmed, holding that the district court (1) erred in instructing the jury on the intent element of burglary, the predicate offense for the felony-murder charge, but the error did not constitute reversible plain error; (2) erred in suggesting the order in which the jury should consider the charges when instructing the jury, but the error was not plain; (3) did not abuse its discretion by excluding alternative-perpetrator evidence of Appellant’s alleged bad acts; and (4) did not violate Minn. R. Crim. P. 26.03(1) by proceeding with the trial in Appellant’s absence. View "State v. Davis" on Justia Law

Appellant was convicted of second-degree unintentional murder. Appellant waived his right to a sentencing jury. The district court imposed a 420-month sentence, an upward durational departure of 168 months, determining that Defendant’s concealment of the victim’s body was an aggravating factor sufficient to justify the upward durational departure. The court of appeals affirmed the sentence. The Supreme Court affirmed, holding that concealment of a murder victim’s body is an aggravating factor on which a district court may base an upward departure, and therefore, the district court did not abuse its discretion when it imposed an upward durational departure on Appellant’s sentence for second-degree unintentional murder. View "State v. Hicks" on Justia Law

In 1988, Appellant pleaded guilty to first-degree murder and attempted first-degree murder. Appellant was sentenced to consecutive terms of life in prison and 130 months. This appeal concerned Appellant’s fifth postconviction petition, in which Appellant claimed that his guilty pleas were not knowing, voluntary, and intelligent. Appellant filed the petition after expiration of the postconviction statute of limitations under Minn. Stat. 590.01(4)(a). The postconviction court summarily denied Appellant’s petition as time-barred. Appellant appealed, arguing that his claim was not time-barred because it satisfied three of the exceptions to the statute of limitations. The Supreme Court affirmed, holding that Appellant’s claim failed to satisfy any of the exceptions to the postconviction statute of limitations under section 590.01(4)(b), and therefore, Appellant's fifth request for postconviction relief was time-barred. View "Brown v. State" on Justia Law

After a jury trial, Appellant was convicted of two counts of first-degree murder, one count of attempted first-degree murder, and one count of burglary. Appellant committed the offenses when he was sixteen years old. The district court imposed a mandatory sentence of life imprisonment with the possibility of release for each first-degree murder conviction. Defendant’s convictions were affirmed on direct appeal. Nineteen years later, Appellant moved to correct his sentence based on the rule announced in Miller v. Alabama. Specifically, Appellant argued that the rule announced in Miller should be extended to statutory provisions that mandate the imposition of life imprisonment with the possibility of release and should apply to a district court’s discretionary imposition of consecutive sentences that are the functional equivalent of life imprisonment without the possibility of release. The postconviction court denied Appellant’s motion. The Supreme Court affirmed, holding that the postconviction court’s decision was consistent with the Court’s recent rulings, and its ruling was a sound exercise of its discretion. View "State v. Williams" on Justia Law