Justia Minnesota Supreme Court Opinion Summaries

Appellant pleaded guilty to one count of third-degree sale of a narcotic drug and was sentenced to fifteen months’ imprisonment. Appellant later sought postconviction relief seeking to withdraw his guilty plea for lack of an adequate factual basis. Specifically, Appellant argued that because the factual basis for his plea was his admission that he gave cocaine to his wife to hide when police officers pulled over the car in which he was a passenger, his testimony at the plea hearing did not support his conviction for a “sale” because he did not admit that he relinquished possession of the controlled substance. The postconviction court denied Appellant’s petition, concluding that the statutory definition of “sell” requires only a physical transfer of the possession of the contraband. The court of appeals affirmed. The Supreme Court reversed, holding (1) the facts to which Defendant admitted during his guilty plea colloquy did not show that his conduct fell within the definition of “sell” in Minn. Stat. 152.01(15a)(1); and (2) because there was not a sufficient factual basis for Appellant’s plea, his motion to withdraw his guilty plea should be granted. View "Barrow v. State" on Justia Law

Pursuant to a plea agreement, Defendant pleaded guilty to second-degree criminal sexual conduct and first-degree aggravated robbery in exchange for the State dismissing several charges. Defendant agreed to receive a sentence that was an upward durational departure. The district court sentenced Defendant according to the terms of the plea agreement. Defendant later filed a requested relief under Minn. R. Crim. P. 27.03(9), arguing that the court had impermissibly sentenced him. The district court denied relief. The court of appeals affirmed, concluding that Defendant could not challenge his sentence in a motion to correct his sentence. The Supreme Court affirmed, holding (1) because Defendant’s challenge to his sentence implicated more than simply his sentence, it is properly viewed as a petition for postconviction relief under Minn. Stat. 590.01, not as a motion to correct a sentence under Rule 27.03; and (2) Defendant’s request is time-barred by section 590.01(4)(a). View "State v. Coles" on Justia Law

After a jury trial, Defendant was convicted of first-degree premeditated murder and sentenced to life imprisonment without the possibility of release. The conviction arose from a homicide that occurred during an aggravated robbery. The Supreme Court affirmed, holding (1) the evidence was sufficient to uphold Defendant’s conviction, as the State introduced sufficient evidence to prove Defendant’s guilt as an accomplice to the murder; and (2) any error in the district court’s admission into evidence of recordings of portions of Defendant’s interrogation that occurred after Defendant told the officers, “ain’t no sense in talking no more man” was harmless beyond a reasonable doubt because the verdict was surely unattributable to the error. View "State v. McAllister" on Justia Law

Appellant pleaded guilty to first-degree sexual conduct. Appellant was sentenced to a term of 144 months. Appellant later filed a petition for postconviction relief seeking to withdraw his guilty plea, alleging that his guilty plea was not knowingly, voluntarily, and intelligently made. The postconviction court denied the request for relief. The court of appeals affirmed, noting that the petition did not meet the basic requirements of the postconviction statute. The Supreme Court affirmed, holding that because Appellant did not provide a single factual allegation to support his claim that his guilty plea was not knowingly, voluntarily, or intelligently made, his petition did not meet the requirements of Minn. Stat. 590.02(1)(1). View "Matakis v. State" on Justia Law

After a jury trial, Appellant was convicted of first-degree premeditated murder and first-degree murder while committing burglary arising from the stabbing death of an eleven-year-old. The Supreme Court affirmed Appellant’s conviction for premeditated first-degree murder but vacated his conviction for first-degree murder while committing burglary. Appellant later filed a petition for postconviction relief arguing that he was entitled to a new trial to consider evidence that was purportedly new and exculpatory. The postconviction court denied the petition without holding an evidentiary hearing. Appellant subsequently brought the instant pro se petition for postconviction relief, alleging ineffective assistance of trial counsel and appellate counsel and loss of evidence claims. The postconviction court summarily denied the petition, concluding (1) appellate counsel’s representation did not fall below an objective standard of reasonableness, and (2) Appellant’s remaining claims were procedurally barred under State v. Knaffla. The Supreme Court affirmed, holding (1) Appellant’s ineffective assistance of appellate counsel claim failed as a matter of law; and (2) Appellant’s remaining claims were time barred. View "Fort v. State" on Justia Law

After a jury trial, Defendant was found guilty of first-degree murder while committing domestic abuse, second-degree intentional murder, second-degree felony murder, and third-degree murder. The Supreme Court (1) reversed Defendant’s first-degree murder conviction and remanded for a new trial on that charge, holding that the district court committed multiple plain errors that, taken cumulatively, affected Defendant’s substantial rights and the fairness, integrity, or public reputation of the judicial proceedings; and (2) Defendant was not entitled to a new trial on the charge of second-degree intentional murder because any alleged error based on the exclusion of Defendant’s preliminary breath test results was harmless beyond a reasonable doubt. View "State v. Bustos" on Justia Law

Appellant was convicted of first-degree premeditated murder and sentenced to life imprisonment without the possibility of release. The Supreme Court affirmed on appeal. Appellant later filed a pro se petition for postconviction relief, raising a sentencing claim, a restitution claim, and several claims of ineffective assistance of counsel and newly discovered evidence. The postconviction court granted relief on Appellant’s sentencing claim but denied relief on his other claims. Appellant appealed, arguing that the postconviction court erred when it denied his claims without an evidentiary hearing. The Supreme Court affirmed, holding that the postconviction court did not err when it summarily denied Appellant’s petition. View "Nissalke v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree premeditated murder for the benefit of a gang, first-degree premeditated murder, and second-degree intentional murder. The trial court sentenced Defendant to life imprisonment without the possibility of release. The Supreme Court affirmed Defendant’s conviction, holding that the trial court did not commit plain error when it admitted as substantive evidence out-of-court statements made to the police by one of the State’s witnesses and when it admitted Spreigl evidence relating to a 2009 shots-fired incident, as the allegedly erroneous admission of the evidence did not affect Defendant’s substantial rights or substantially influence the verdict. View "Ramsey County v. Campbell" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and sentenced to life in prison. The Supreme Court affirmed on direct appeal. Defendant subsequently filed four petitions for postconviction relief as well as a motion for postconviction DNA testing. All five postconviction petitions or motions were denied. In his sixth petition, Defendant argued that he received ineffective assistance of counsel because he was not informed of a plea offer purportedly discussed during an in-chambers meeting that occurred during his trial. The postconviction court denied Defendant’s petition without an evidentiary hearing, concluding that his claim was both time barred and procedurally barred. The Supreme Court affirmed, holding that Defendant’s petition was untimely under Minn. Stat. 590.01(4)(a), and neither of the exceptions upon which he relied applied in this case. View "Wayne v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder while committing a drive-by shooting. The district court imposed a life sentence with the possibility of release. After the Supreme Court affirmed on appeal, Defendant filed several petitions for postconviction relief. Defendant's third and fourth petitions asserted claims of newly discovered evidence. The postconviction court denied Defendant’s third and fourth petitions after an evidentiary hearing, determining that because the witnesses who testified on Defendant’s behalf were not credible, the evidence that Defendant presented as newly discovered failed to satisfy the materiality requirement of the newly discovered evidence test set forth in Rainer v. State. The Supreme Court affirmed, holding that the postconviction court did not abuse its discretion in denying Defendant’s third and fourth petitions for postconviction relief. View "Bobo v. State" on Justia Law