Justia Minnesota Supreme Court Opinion Summaries

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

Defendant pled guilty to a fourth-degree controlled substance violation. After finding that Defendant was a career offender under Minn. Stat. 609.1095(4), the district court imposed a sentence of sixty-six months, a double upward departure from the thirty-three-month presumptive sentence under the Minnesota Sentencing Guidelines. The court of appeals reversed and remanded for resentencing, concluding (1) one of Defendant’s felony convictions did not meet the requirements of the career-offender statute because it had been deemed a misdemeanor before Defendant was sentenced, and (2) therefore, Defendant could not be sentenced as a career offender because he did not have five prior felony convictions. The Supreme Court affirmed, holding that, under the plain language of section 609.1095(4), a felony conviction that has been deemed a misdemeanor by operation of Minn. Stat. 609.13 before an offender is sentenced for the current offense may not be considered when determining whether the offender has five or more prior felony convictions. View "State v. Franklin" on Justia Law

Law enforcement officers searched Defendant’s home pursuant to a search warrant and found plastic bags containing methamphetamine. The search warrant was based on information police received from a warrantless search of Defendant’s garbage. Defendant was charged with third-degree possession of a controlled substance. Defendant moved to suppress the evidence, arguing that the warrantless search of his garbage violated Minn. Const. art. I, 10. The district court denied the motion to suppress. The court of appeals affirmed. At issue before the Supreme Court was whether Article I, Section 10 of the Minnesota Constitution requires greater protection than the Fourth Amendment to the United States Constitution in the context of a warrantless search of garbage set out for collection in an area accessible to the public. The Supreme Court affirmed, holding (1) there is not a principled basis for interpreting Article I, Section 10 to require greater protection that the Fourth Amendment; (2) it was lawful for the police to obtain Defendant’s garbage from the garbage collector; and (3) because the warrantless search of Defendant’s garbage was reasonable under the state and federal constitutions, the search warrant for Defendant’s residence based on evidence found in the garbage was valid. View "State v. McMurray" on Justia Law

Defendant was convicted of a violation of Minn. Stat. 97B.301, which states that a person may not “take” deer without a license, after he was discovered sitting in a camouflaged blind in an open field, wearing blaze orange, and possessing a loaded gun. At issue on appeal was whether Defendant’s actions constituted a “take” under the applicable definition. The court of appeals affirmed. The Supreme Court also affirmed, holding (1) the statutory definition of “taking” applies to “take”; and (2) under that definition, a jury could reasonably conclude that Defendant took deer by “pursuing” or “attempting to take” deer in violation of section 97B.301. View "State v. Schmid" on Justia Law

Appellant was convicted of a crime and was sentenced to a stayed sentence of ninety-eight months together with a conditional-release term of five years. Appellant violated his probation, served a portion of his executed sentence, and was then placed on supervised release. After Appellant violated the terms of his supervised release, the Minnesota Department of Corrections (DOC) revoked his release and ordered him to serve the remaining portion of his executed sentence in custody. Appellant filed a motion to correct his sentence under Minn. R. Crim. P. 27.03(9), alleging that the DOC had illegally extended his conditional-release term. The district court concluded that it had jurisdiction over the matter and denied Appellant’s motion to correct his sentence on the merits. The Supreme Court affirmed as modified, holding (1) the district court has subject matter jurisdiction over a motion to correct a sentence under Rule 27.03(9), but such a motion is not the proper procedure to obtain judicial review of the Commissioner of Correction’s administrative decision implementing the sentence imposed by the district court; and (2) because Appellant used the wrong procedure, a denial of his motion to correct his sentence was warranted. View "State v. Schnagl" on Justia Law

Minn. Stat. 169A.20(2) (“the test refusal statute”) makes it a crime for a driver to refuse to request to take a chemical test to detect the presence of alcohol if certain conditions are met. One of those conditions is that the driver has been validly arrested for driving while impaired. Appellant argued that the test refusal statute violated due process because it criminalizes refusal to consent to an unreasonable, warrantless search of a driver’s breath. The district court dismissed the charges, concluding that the police lacked a lawful basis to search Appellant without a warrant, and therefore, the test refusal statute was unconstitutional as applied. The court of appeals reversed. The Supreme Court affirmed, holding (1) because the breath test the police asked Defendant to take would have been constitutional under the search-incident-to-arrest exception to the Fourth Amendment’s warrant requirement, charging Defendant with criminal test refusal did not implicate a fundamental right; and (2) the test refusal statute is a reasonable means to a permissive object and passes rational basis review. View "State v. Bernard" on Justia Law

After a jury trial, Appellant was convicted of premeditated first-degree murder and attempted first-degree murder. In a postconviction motion, Appellant argued that he was entitled to a new trial based on newly discovered evidence and the recantation of two witnesses. The postconviction court denied the petition after granting multiple continuances for Appellant to attempt to secure the appearance of favorable witnesses and then holding an evidentiary hearing. The Supreme Court affirmed on the merits but remanded for resentencing, holding (1) the postconviction court did not err when it refused to compel the attendance of certain witnesses at an evidentiary hearing; (2) Appellant forfeited his argument that his trial counsel provided ineffective assistance; and (3) the sentence imposed after a remand from Appellant’s direct appeal was improper. Remanded for resentencing. View "Burrell v. State" on Justia Law