Justia Minnesota Supreme Court Opinion Summaries

The State charged Respondents with first-degree burglary under Minn. Stat. 609.582 for breaking into a home and allegedly stealing a locked safe that contained a handgun. The district court dismissed the first-degree burglary charges for lack of probable cause, concluding that section 609.582(1)(b), which requires possession of a dangerous weapon during the burglary, requires knowing possession of a dangerous weapon during the burglary. The Supreme Court reversed, holding (1) section 609.582(1)(b) does not include a mens rea requirement with respect to a defendant’s possession of a dangerous weapon; and (2) therefore, the district court erred in reading an additional knowledge requirement into the statute. View "State v. Garcia-Gutierrez" on Justia Law

After a jury trial, Defendant was found guilty of felony failure to pay child support. After Defendant filed his notice of appeal, the district court issued a warrant for Defendant’s arrest because Defendant failed to appear for a hearing on an alleged probation violation. The State moved to dismiss Defendant’s appeal on the ground that he was a fugitive who had forfeited his right to an appeal. The court of appeals denied the motion on the grounds that Minnesota has not yet adopted the fugitive-dismissal rule. On review, the Supreme Court adopted the fugitive-dismissal rule, holding that appellate courts have the discretion to dismiss an appeal brought by a fugitive. The Court then reversed and directed the court of appeals to dismiss Defendant’s appeal if he did not surrender within ten days, holding that Defendant was a fugitive and his status as a fugitive granted an appellate court the discretionary authority to dismiss his appeal. View "State v. Hentges" on Justia Law

Appellant Ronald Greer sought post-conviction relief from his murder conviction. The trial court denied relief, and he appealed that denial to the Supreme Court. Finding that the trial court did not abuse its discretion in denying Greer's petitions for relief, the Supreme Court affirmed. View "Greer v. Minnesota" on Justia Law

After a jury trial, Appellant was convicted of two counts of first-degree premeditated murder, two counts of first-degree felony murder, and three counts of first-degree aggravated robbery. The Supreme Court affirmed Appellant's convictions, holding that the district court did not err by (1) overruling Defendant's Batson objection to the State's peremptory challenge of an African-American prospective juror, as Defendant failed to prove that the challenge constituted purposeful racial discrimination; and (2) admitting evidence that Defendant assaulted and threatened a witness two days before trial to prove consciousness of guilt, as the district court correctly weighed the probative value of the evidence against the danger of unfair prejudice and provided safeguards to ensure the evidence would not unduly influence the jury's verdict.View "State v. Diggins" on Justia Law

Defendant was convicted of two counts of aiding suicide in violation of Minn. Stat. 609.215(1), which makes it illegal to intentionally “advise, encourage, or assist another in taking the other’s own life.” Defendant had responded to posts on suicide websites by encouraging the victims to hang themselves, falsely claiming that he would also commit suicide. Defendant appealed, arguing that section 609.215(1) violated the First Amendment. The court of appeals affirmed, holding that the statute prohibited speech that was unprotected by the First Amendment. The Supreme Court reversed, holding (1) the State may prosecute Defendant for assisting another in committing suicide but not for encouraging or advising another to commit suicide, and thus the words “advises” and “encourages” must be severed from the statute as unconstitutional; and (2) because the district court did not make a specific finding on whether Defendant assisted the victims’ suicides, the case must be remanded. View "State v. Melchert-Dinkel" on Justia Law

Respondent was charged by juvenile petition, as both a principal and an accomplice, with criminal sexual conduct and other crimes arising out of the rape of a fourteen-year-old girl. After a hearing, the juvenile court concluded that Respondent had not overcome the presumption in favor of certification to adult court and certified Respondent for prosecution as an adult. The court of appeals reversed, concluding that the juvenile court abused its discretion by failing to expressly weigh the seriousness of the alleged offense and Respondent’s prior record of delinquency separate from other public safety factors and by failing to specifically delineate how its determination of the two factors impacted its certification decision, as required by Minn. Stat. 260B.125. The Supreme Court reversed, holding (1) the court of appeals erroneously interpreted section 260B.125(4); and (2) the juvenile court did not abuse its discretion by concluding that Respondent failed to overcome the presumption in favor of certification. View "In re Welfare of J.H." on Justia Law

Defendant, who was HIV positive, engaged in consensual anal intercourse. Defendant was subsequently charged with attempted first-degree assault by transferring a communicable disease for violating Minn. Stat. 609.2241(2). A jury found Defendant violated section 609.2241(2)(2), which applies to the "transfer of blood, sperm, organs, or tissue." The court of appeals reversed the conviction, concluding that section subdivision 2(2) applies only to medical procedures instead of applying to acts of sexual conduct. The Supreme Court affirmed, holding (1) subdivision 2(2) applies only to the donation or exchange for value of blood, sperm, organs, or tissue; and (2) because Defendant's conduct indisputably did not involve the donation or exchange for value of his sperm, subdivision 2(2) was inapplicable to Defendant's conduct.View "State v. Rick" on Justia Law

After a jury trial, Defendant was convicted of criminal vehicular homicide for causing the death of ninety-three-year-old Edith Schouveller in a motor vehicle accident. The accident occurred on March 28, 2010. Schouveller was transported to the hospital with several life-threatening injuries. For the next twenty-two days, Schouveller was either hospitalized or in a nursing home. Schouveller developed lung problems while in the hospital, which led to pneumonia. On April 19, 2010, Schouveller experienced acute respiratory failure. Doctors determined that she needed to be placed on a respirator in order to continue to live, but relying on Schouveller's living will, the doctors declined to place her on respiratory support. Schouveller died that evening. The Supreme Court affirmed Defendant's conviction, holding (1) the district court properly instructed the jury on causation; (2) the State presented sufficient evidence to demonstrate a causal chain between the injuries Shouveller sustained in the accident and the pneumonia and aspiration that ultimately led to her death; and (3) the evidence was sufficient for the jury to conclude that the do-not-resuscitate order in Souveller's living will was not a superseding cause of her death. View "State v. Smith" on Justia Law

Defendant was convicted of murder in the first degree while committing domestic abuse and with a past pattern of domestic abuse. Defendant subsequently filed a petition for postconviction relief, arguing, among other things, that there was insufficient evidence to establish a past pattern of domestic abuse beyond a reasonable doubt. After an evidentiary hearing, the postconviction court denied the petition. The Supreme Court affirmed, holding (1) sufficient evidence supported the jury’s finding that Defendant engaged in a past pattern of domestic abuse against the victim; (2) the district court did not err in its jury instructions on a past pattern of domestic abuse; and (3) the district court did not commit plain error by admitting evidence connected to orders for protection obtained by the victim, as Appellant’s substantial rights were not affected by the admission of this evidence. View "Gulbertson v. State" on Justia Law

Law enforcement officers stopped a truck driven by Thomas Anthony, a suspected drug dealer. Charles Lemert was a passenger in Anthony’s car. Officers ordered Lemert to get out of the truck and proceeded to conduct a pat search of Lemert. Based on the evidence discovered during the pat search, the State charged Lemert with a fifth-degree controlled-substance offense. Lemert moved to suppress the evidence, arguing that the search was unlawful because the officers lacked a reasonable, articulable suspicion that Lemert might have been armed and dangerous. The district court denied the motion and convicted Lemert of the charge. The court of appeals affirmed. The Supreme Court affirmed, holding that, under the circumstances, the officers had a reasonable, articulable suspicion that Lemert might have been armed and dangerous, and therefore, the district court did not err when it denied Lemert’s motion to suppress. View "State v. Lemert" on Justia Law