Justia Minnesota Supreme Court Opinion Summaries

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

Appellant was convicted of two counts of criminal sexual conduct arising from separate behavioral incidents with separate victims. The district court concluded that Appellant was not subject to lifetime conditional release under Minn. Stat. 609.3455(7)(b) because the two convictions were entered at the same hearing, and therefore, Defendant under not have a “prior sex offense conviction” under section 609.344(1)(g). The Supreme Court reversed, holding that Defendant was subject to lifetime conditional release because the definition of “prior sex offense conviction” unambiguously includes a conviction for a separate behavioral incident entered before a second conviction, whether at different hearings or during the same hearing. Remanded. View "State v. Nodes" on Justia Law

Defendant was convicted of three counts of murder in connection with the death of his two-year-old niece. While Defendant’s appeal was pending, new evidence was identified. The State then sought, and a grand jury returned, an amended indictment for five counts of murder. After a new trial, Defendant was convicted of five counts of murder. The Supreme Court reversed, holding that the district court (1) did not err when it seated jurors who knew about Defendant’s first conviction; but (2) abused its discretion when it allowed a juror who exhibited actual bias against Defendant and was not adequately rehabilitated to sit in judgment of Defendant. Remanded for a new trial. View "State v. Fraga" on Justia Law

After a jury trial, Appellant was found guilty of first-degree premeditated murder and first-degree felony murder. The district court sentenced Appellant to life imprisonment without the possibility of release on the first-degree premeditated murder conviction. The Supreme Court affirmed, holding (1) the district court did not err in denying Appellant’s motion to suppress statements he made to police; (2) the district court did not abuse its discretion when it declined to give Appellant’s requested jury instruction on circumstantial evidence; and (3) the evidence was sufficient to support Appellant’s murder convictions. View "State v. Fox" on Justia Law

After a jury trial, Appellant was found guilty of failing to register as a predatory offender. The district court imposed a presumptive sentence of sixteen months imprisonment and a ten-year conditional-release term under Minn. Stat. 422.052(3). The court imposed the conditional-release term based on a previous finding by an administrative committee of the Department of Corrections that had assessed Appellant as a high-risk, level-III offender. Several years later, Appellant moved to correct his sentence, arguing that a jury, not the judge, was constitutionally required to make the finding regarding his risk-level status. The district court denied Appellant’s motion. The court of appeals affirmed. The Supreme Court reversed and vacated Appellant’s ten-year conditional-release term, holding that Appellant had the right to have a jury determine whether he was a risk-level-III offender at the time of his offense. View "State v. Her" on Justia Law