Justia Minnesota Supreme Court Opinion Summaries

After a jury trial in 1994, Defendant was convicted of first-degree murder and sentenced to life in prison with the possibility of release. Seven months later, Defendant pleaded guilty to second-degree attempted murder. The court sentenced Defendant to an additional seventy-two months in prison to run consecutively to his life sentence. In 2012, Defendant filed a pro se motion to correct his sentence under Minn. R. Crim. P. 27.03(9). The district court treated the motion as a petition for postconviction relief and then denied the motion on the grounds it was time barred and procedurally barred. The Supreme Court affirmed, holding that even if Defendant's motion was not time barred or procedurally, barred, his argument that the overall length of his imprisonment should be reduced failed on the merits.View "Townsend v. State" on Justia Law

Appellant was convicted of felony-level failure to provide care and support to his children due to his omission and failure to pay court-ordered child support. The court of appeals affirmed the conviction, concluding (1) the phrase “care and support” in Minn. Stat. 609.375(1) refers exclusively to a person’s financial obligations to a spouse or child; and (2) the district court did not err when it excluded Appellant’s evidence that he had provided nonmonetary care to his children. The Supreme Court reversed, holding (1) to obtain a conviction under section 609.375(1) the State must prove beyond a reasonable doubt that a defendant knowingly omitted and failed to provide both care and support to a spouse or child; and (2) the State did not present any evidence that Appellant knowingly omitted and failed to provide care to his children, and therefore, insufficient evidence supported Appellant’s conviction under the care-and-support statute. View "State v. Nelson" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and sentenced to life in prison. Defendant subsequently filed two petitions for postconviction relief, both of which were denied. The instant appeal concerned the postconviction court’s summary denial of Defendant’s second petition for postconviction relief. On appeal, Defendant raised three claims: ineffective assistance of appellate counsel, prosecutorial misconduct, and ineffective assistance of trial counsel. The Supreme Court affirmed, holding that the postconviction court did not err by summarily denying Defendant’s second petition for postconviction relief because all three of Defendant’s claims failed as a matter of law. View "Erickson v. State" on Justia Law

After a jury trial, Appellant was found guilty of first-degree murder of a peace officer, four counts of first-degree assault, and other offenses connected with the shooting death of a county deputy sheriff officer. The Supreme Court reversed one of the first-degree assault convictions but otherwise affirmed, holding (1) the district court did not abuse its discretion when it transferred venue to Polk County; (2) the murder prosecution was not barred by the common law “year-and-a-day rule” because the victim died eighteen months after the shooting, as the year-and-a-day rule does not apply to the Minnesota law of homicide; (3) the district court did not abuse its discretion by admitting into evidence certain photographs; and (4) the evidence was insufficient to support Defendant’s conviction on one of the first-degree assault counts. View "State v. Fairbanks" on Justia Law

Respondent, a criminal defendant, successfully filed a motion to suppress, which the State appealed. The court of appeals reversed the order granting the motion to suppress. Defendant filed a motion for attorney fees, requesting that his attorney receive $120 per hour for 30.3 hours of work performed on the appeal. The State opposed the motion, contending that the court was required to use the rate of $50 an hour set in a standing order of the district court to that portion of the work defense counsel performed after the order was issued. The court of appeals granted the amount Respondent requested. The Supreme Court affirmed, holding that, under the circumstances, the court of appeals did not abuse its discretion in awarding Respondent a consistent hourly rate of $120 per hour for attorney fees and awarding him his full attorney-fee request. View "State v. Williams" on Justia Law

After a jury trial, Appellant was convicted of several offenses, including first-degree felony murder. Appellant subsequently filed several petitions for postconviction relief. This appeal concerned the denial of Appellant’s fourth postconviction petition. Appellant argued that the postconviction court erred in summarily denying Appellant’s fourth postconviction petition as untimely under Minn. Stat. 590.01(4). Appellant contended that the earlier appeal of the denial of his third postconviction petition was a “direct appeal,” and therefore, his fourth postconviction petition was timely filed under section 590.01(4)(a)(2) because the fourth petition was filed within two years of “an appellate court’s disposition of the petitioner’s direct appeal.” The Supreme Court affirmed the summary denial of Appellant’s fourth postconviction petition, holding (1) Appellant’s reliance on section 590.01(4)(a)(2) was misplaced because his earlier appeal of his third postconviction petition was not a direct appeal; and (2) the petition, files, and records conclusively showed that Appellant’s fourth petition was time barred. View "Staunton v. State" on Justia Law

Law enforcement officers obtained a warrant to search Appellant and Appellant’s residence after Appellant allegedly threatened a woman for stealing his drugs. At the apartment the officers seized gun and drug evidence. Appellant filed a motion to suppress, which the district court granted on the ground that the search warrant affidavit failed to establish a sufficient nexus between Defendant’s alleged criminal activity and the apartment. The court of appeals reversed. The Supreme Court affirmed, holding that, based on the totality of the circumstances, the search warrant affidavit established a sufficient nexus between Appellant’s alleged criminal activity and the place to be searched. View "State v. Yarbrough" on Justia Law

Appellant pleaded guilty to first-degree driving while impaired (DWI). After receiving a notice advising him of the County’s intent to forfeit his vehicle pursuant to Minn. Stat. 169A.63, Appellant sought a judicial determination of the forfeiture, arguing that he was entitled to a portion of the value of the forfeited vehicle under the motor vehicle exemption, Minn. Stat. 550.37(12)(a). The district court granted summary judgment for the County on behalf of respondent vehicle, holding that the motor vehicle exemption does not apply when a vehicle is forfeited pursuant to section 169A.63. The Supreme Court affirmed, holding that neither the motor vehicle exemption nor Minn. Const. art I, 12 applies to DWI forfeiture pursuant to section 169A.63. View "Nielsen v. 2003 Honda Accord" on Justia Law

After a jury trial, Appellant was convicted of first-degree felony murder while committing a drive-by shooting for the benefit of a gang. The Supreme Court stayed Appellant’s direct appeal to permit Appellant to file a petition for postconviction relief. The postconviction court subsequently denied relief. The Supreme Court consolidated Appellant’s direct and postconviction appeals into a single proceeding and held (1) the record contained sufficient evidence to support Appellant’s conviction; (2) some of the individual jury instructions in this case were erroneous, but the jury instructions, considered as a whole, did not constitute reversible error; (3) Appellant knowingly and voluntarily waived his right to testify at trial; (4) Appellant was not deprived of his right to the effective assistance of trial counsel; (5) the district court did not abuse its discretion when it denied Appellant’s motion for a mistrial; (6) the jury did not return legally inconsistent verdicts; and (7) the postconviction court did not err when it denied an evidentiary hearing on Appellant’s claim that the district court violated his right to a public trial. View "State v. Bahtuoh" on Justia Law

Defendant was convicted of first-degree murder and sentenced to life imprisonment. The Supreme Court affirmed the conviction on direct appeal. Defendant subsequently filed several petitions for postconviction relief. Defendant's fourth petition for postconviction relief alleged that new evidence, an unsworn statement by an alleged eyewitness to the murder, entitled him to a new trial. After an evidentiary hearing, the postconviction court denied Defendant's fourth petition for postconviction relief. The Supreme Court affirmed, holding that the postconviction court (1) did not err in denying Defendant a new trial based on new evidence; (2) did not abuse its discretion in how it handled evidence that Defendant submitted after the evidentiary hearing; and (3) did not err in refusing to grant relief in the interests of justice. View "Miles v. State" on Justia Law