Justia Minnesota Supreme Court Opinion Summaries

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

An airport police narcotics investigator removed a package, which was addressed to Defendant, from a conveyor belt at the UPS mail area at the Minneapolis-Saint Paul International Airport, and placed the package on the floor. A trained narcotics-detection dog was brought into the area and alerted to the package. Based on the dog’s alert, an airport police narcotics investigator obtained a warrant authorizing him to open and search the package, which contained cocaine and methamphetamine. Appellant was charged with two counts of a first-degree controlled substance crime. Appellant filed a motion to suppress, arguing that the movement of the package to the floor constituted a seizure, that the dog sniff constituted a search, and that the package was seized and searched without a reasonable, articulable suspicion of criminal activity. The district court denied Petitioner’s motion, concluding that the detention and dog sniff did not constitute a search or seizure. The court of appeals affirmed on other grounds, determining that there was both a search and a seizure but that there was reasonable, articulable suspicion for both. The Supreme Court affirmed on the same basis as the district court, holding that there was neither a search nor a seizure under the facts of this case. View "State v. Eichers" on Justia Law

Police officers followed a Chevrolet Monte Carlo that drove away from a house suspected of hosting drug trafficking. The officers subsequently stopped the vehicle after learning that the Monte Carlo’s registration had been revoked and that it was registered to Defendant, whose driver’s license had also been revoked. The driver, who was identified as Defendant, indicated that the car was not insured. The officers decided to tow and impound the vehicle. During an inventory search, the officers found drug and drug paraphernalia in a purse on the passenger seat of the Monte Carlo. Defendant was charged with possession of a controlled substance and possession of drug paraphernalia. Defendant filed a motion to suppress, aruing that the initial stop was lawful but that the search was unconstitutional because the police were not authorized to impound the vehicle, and the inventory search itself was pretextual. The district court denied the motion. The court subsequently found Defendant guilty on both counts. The Supreme Court reversed, holding that the impoundment was unreasonable, and therefore, the resulting inventory search was unconstitutional. View "State v. Rohde" on Justia Law

Defendant was charged with third-degree assault. Defendant’s defense theory was that he acted in self-defense during a hallway confrontation with a non-resident of his apartment building. Before the case was submitted to the jury, the district court instructed the jury that Defendant had a duty to retreat if reasonably possible before acting in self-defense. A jury subsequently found Defendant guilty of third-degree assault and the lesser included offense of fifth-degree assault. The court of appeals affirmed. The Supreme Court affirmed, holding that Defendant had a duty to retreat if reasonably possible while in a non-exclusive hallway of his apartment building. View "State v. Devens" on Justia Law

The State filed a complaint against Defendant charging him with third- and fourth-degree criminal sexual conduct. Defendant waived his right to a jury trial during a pretrial hearing. Thereafter, the State filed an amended complaint adding a charge of first-degree criminal sexual conduct. Defendant did not personally waive his right to a jury trial on the amended charge. Defendant was subsequently found guilty of all three counts. Defendant appealed, arguing that the district court erred when it failed to obtain a personal waiver of his right to a jury trial after the State amended the complaint. The court of appeals affirmed Defendant’s first-degree sexual conduct conviction. The Supreme Court reversed the court of appeals, vacated Defendant’s conviction for first-degree criminal sexual conduct, and remanded, holding (1) when the State charges a defendant with an additional offense after the defendant has waived his or her right to a jury trial, the court must obtain a new waiver before dispensing with a jury; and (2) in this case, the district court’s failure to obtain a personal waiver of Defendant’s right to a jury trial on the charge of first-degree criminal sexual conduct constituted a plain error that affected Defendant’s substantial rights. View "State v. Little" on Justia Law