Justia Minnesota Supreme Court Opinion Summaries

Appellant pleaded guilty and was convicted of first-degree burglary. Two years after Appellant was placed on probation, he appeared before the district court regarding alleged probation violations. Appellant personally admitted the probation violations, and the district court revoked his probation. On appeal, Appellant argued for the first time that the district court erred when it violated his constitutional right to be advised of his due process rights under Morrissey v. Brewer and when it failed to provide him the rights advisory required by Minn. R. Crim. P. 27.04. The court of appeals affirmed. The Supreme Court affirmed, holding (1) a probationer does not have a separate constitutional right “to be advised” that he or she has the procedural due process rights articulated in Morrissey; and (2) the district court’s plain error in failing to provide Appellant the rights advisory requirement by Rule 27.04 did not affect his substantial rights. View "State v. Beaulieu" on Justia Law

After a jury trial, Appellant was convicted of first-degree domestic-abuse murder and two counts of second-degree murder. Appellant was sentenced to life imprisonment with the possibility of release. The Supreme Court affirmed, holding (1) two courtroom closures did not violate Defendant’s Sixth Amendment right to a public trial because Defendant requested the courtroom closures, and the closures did not seriously affect the fairness, integrity, or public reputation of the judicial proceedings; and (2) any error in the admission of relationship evidence under Minn. Stat. 634.20 of Defendant’s past incidents of domestic abuse against his sister and his former girlfriend was harmless. View "State v. Benton" on Justia Law

Upon executing a warrant to search Defendant’s home for stolen property, law enforcement officers found a locked gun safe in the bedroom. Inside the gun safe were a sawed-off shotgun, a full-length shotgun, and a pistol. No evidence identified Defendant as the owner of the sawed-off shotgun or the pistol. After a jury trial, Defendant was convicted of being a felon in possession of a firearm, in possession of a firearm with no serial number, and in possession of a short-barreled shotgun. Defendant appealed, arguing that there was insufficient evidence that he constructively possessed the firearms in the locked safe. The court of appeals affirmed. The Supreme Court affirmed, holding that under the first prong of State v. Florine, the State established Defendant’s constructive possession of the guns by direct evidence, and therefore, the evidence was sufficient to support the convictions. View "State v. Salyers" on Justia Law

After a jury trial, Petitioner was convicted of aiding and abetting first-degree premeditated murder and sentenced to life in prison without the possibility of release. The Supreme Court affirmed the conviction. Thereafter, Petitioner filed a petition for postconviction relief, alleging that Eric Bermea, who testified as an eyewitness at the trial, had provided false testimony and had subsequently recanted that testimony. The postconviction court denied the petition without an evidentiary hearing. The Supreme Court affirmed, holding that because the absence of Bermea’s testimony would not have changed the jury’s verdict to an acquittal or to a conviction of a lesser charge, the postconviction court did not abuse its discretion in denying Petitioner’s petition without an evidentiary hearing. View "Ortega v. State" on Justia Law

Appellant pleaded guilty to first-degree criminal sexual conduct in return for the State recommending the presumptive sentence under the Minnesota Sentencing Guidelines - twelve years executed. After a sentencing hearing, the district court sentenced Appellant to twelve years in prison but stayed the sentence and put Appellant on supervised probation for thirty years. The court of appeals reversed and remanded for execution of the presumptive twelve-year prison sentence. The Supreme Court granted Appellant’s petition for review, vacated the judgment of the court of appeals, and remanded, holding that the district court abused its discretion in departing from the Sentencing Guidelines. View "State v. Soto" on Justia Law

After a jury trial, Appellant was convicted as an accomplice to first-degree aggravated robbery and third-degree assault. Appellant appealed, contending that he was entitled to a new trial because a jury instruction on accomplice liability plainly violated the newly announced rule in State v. Milton. The court of appeals affirmed, concluding that the accomplice liability instruction was legally erroneous but that Appellant was not entitled to relief under Minn. R. Crim. P. 31.02 because the law was unsettled at the time of the error and did not become settled in favor of Appellant until the time of appeal. The Supreme Court affirmed as modified, holding (1) Rule 31.02 is not limited to errors that were plain at the time of trial, but, rather, under this rule a court must examine the law in existence at the time of appellate review; but (2) Appellant in this case was not entitled to a new trial because the alleged error did not affect Appellant’s substantial rights. View "State v. Kelley" on Justia Law

After a jury trial, Appellant was convicted of one count of first-degree premeditated murder and two counts of first-degree felony murder. The Supreme Court consolidated Appellant’s direct appeal and his postconviction appeal and held (1) the mandatory imposition of life without the possibility of release (LWOR) on the first-degree premeditated murder conviction violated the Eighth Amendment’s prohibition on cruel and unusual punishment under Miller v. Alabama; and (2) the postconviction court did not err in denying postconviction relief, the district court did not err in its evidentiary rulings or in imposing consecutive sentences, and the arguments Appellant raised in a pro se supplemental brief were without merit. Remanded for resentencing on the first-degree premeditated murder conviction. View "State v. Ali" on Justia Law

Following a bench trial, Appellant was convicted of three counts of first-degree premeditated murder and sentenced to three consecutive life sentences without the possibility of release. The Supreme Court affirmed Appellant’s convictions on direct appeal, holding (1) the district court did not err in admitting an in-court identification of Appellant; (2) the district court did not abuse its discretion in excluding Appellant’s proposed expert testimony regarding the problems with eyewitness identification; and (3) Appellant was not entitled to a new trial based on alleged prosecutorial misconduct in eliciting three types of inadmissible character evidence. View "State v. Mosley" on Justia Law

Appellant was convicted of first-degree premeditated murder for the benefit of a gang and related offenses and was sentenced to life in prison without the possibility of release. In his third petition for postconviction relief, Appellant alleged that three witnesses testified falsely at his trial. The postconviction court denied Appellant’s petition without an evidentiary hearing. The Supreme Court reversed, holding that Appellant alleged facts that, if proven, would entitle him to relief, and therefore, the postconviction court abused its discretion when it failed to grant Appellant an evidentiary hearing in connection with his petition. Remanded for an evidentiary hearing. View "Caldwell v. State" on Justia Law

Appellant was charged with, and pleaded guilty to, first-degree murder while committing domestic abuse. The district court accepted Appellant’s guilty plea, convicted him, and sentenced him to life imprisonment with the possibility of release. Appellant later filed a motion to withdraw his guilty plea, asserting that enforcing his guilty plea was manifestly unjust because the plea was not accurate, intelligent, or voluntary. The postconviction court denied relief. The Supreme Court affirmed. Appellant then filed a second postconviction petition, alleging that his guilty plea was inaccurate and that the attorney who represented him on his first postconviction petition provided ineffective assistance. The postconviction court denied the petition without an evidentiary hearing. The Supreme Court affirmed, holding that the postconviction court (1) did not abuse its discretion when it concluded that Appellant’s challenge to his guilty plea was procedurally barred; and (2) did not abuse its discretion when it summarily denied Appellant’s ineffective assistance of postconviction counsel claim because the petition and records conclusively showed that Appellant was not entitled to relief. View "Lussier v. State" on Justia Law