Justia Minnesota Supreme Court Opinion Summaries

Defendant Randolph Johnson was charged with felony domestic assault and misdemeanor fifth-degree assault. As part of a negotiated plea, Defendant pleaded guilty to an amended charge of misdemeanor domestic assault, and the State dismissed the felony charge. The district court ordered that Defendant submit to a DNA sample pursuant to Minn. stat. 609.117, subd. 1(1), which requires a defendant charged with a felony and then convicted of a misdemeanor arising out of the same set of circumstances to submit a DNA sample for the limited purpose of criminal identification, after concluding that the statute was constitutional as applied to Defendant. The Supreme Court affirmed after applying a totality-of-the-circumstances test, holding (1) the State's legitimate governmental interests in conducting a search of Defendant to collect a biological specimen for criminal identification purposes outweighed Defendants' reduced expectation of privacy following his misdemeanor conviction arising out of the same set of circumstances as his felony charge; (2) consequently, the statute did not violate the prohibitions against unreasonable searches and seizures in the state and federal constitutions; and (3) Defendant's equal protection claim failed. View "State v. Johnson" on Justia Law

Appellant Darryl Colbert was convicted of premeditated first-degree murder. The Supreme Court affirmed Colbert's conviction on direct appeal. Colbert subsequently filed five petitions for postconviction relief, and the postconviction court denied each petition. In this case, Colbert appealed the postconviction court's denial of his fifth petition for postconviction relief. The Supreme Court affirmed, holding that Colbert's petition was time-barred under Minn. Stat. 590.01, subd. 4, which states that a person seeking relief has two years from the disposition of the person's direct appeal to file a petition for postconviction relief, because it was filed more than two years after it arose. View "Colbert v. State" on Justia Law

Michael Ferguson was convicted of one count of felony drive-by shooting at an occupied building and eight counts of second-degree assault, arising out of an incident in which multiple shots were fired at a duplex occupied by eight people. After Ferguson successfully appealed his original sentence, the district court imposed sentence on the drive-by shooting conviction and all eight assault convictions. On appeal, the court of appeals held that Minn. Stat. 609.035 required the district court to sentence Ferguson only on the drive-by shooting at an occupied building conviction. The Supreme Court reversed the court of appeals and upheld the sentence imposed by the district court, holding that the court of appeals misapplied the rule that a district court may not sentence a defendant to more than one crime for each victim, and that a single sentence for drive-by shooting at an occupied building was not commensurate with Ferguson's culpability for using a dangerous weapon to intentionally cause eight persons to fear immediately bodily harm. View "State v. Ferguson" on Justia Law

Appellant Gary Roby was convicted of aiding and abetting the crimes of first-degree premeditated murder, first-degree murder while committing aggravated robbery, and second-degree intentional murder. The Supreme Court affirmed Roby's conviction on appeal. Roby subsequently filed this, his third petition for postconviction relief, arguing that newly discovered evidence should be considered in the interests of justice. The postconviction court denied Roby's petition without an evidentiary hearing, holding (1) Roby's claims that were based on a 1989 police report and a 2002 letter were time-barred, and (2) Roby's remaining claims failed on the merits. The Supreme Court affirmed, holding (1) all of Roby's claims were time-barred under the postconviction statute, and (2) Roby was not entitled to relief through application of the doctrine of equitable tolling. View "Roby v. State" on Justia Law

Appellant Brent Kuhlmann was convicted after a jury trial of domestic assault and test refusal. On appeal, Appellant argued that the trial court committed reversible error when it accepted a stipulation on elements of the charged offenses without advising him of his right to a jury trial on these elements and securing, either in writing or on the record, his personal waiver of the right to a jury trial on the stipulated elements. The court of appeals affirmed Appellant's convictions. The Supreme Court affirmed, holding (1) the trial court erred in failing to obtain Appellant's personal waiver of the right to a jury trial on the previous-conviction elements of the charged offenses; (2) the trial court's failure to obtain Appellant's personal waiver of his right to a jury trial did not amount to structural error; and (3) under the plain error standard, the error did not affect Appellant's substantial rights or the outcome of the case. View "State v. Kuhlmann" on Justia Law

After a jury trial, Brett Borg was found guilty of third-degree criminal sexual conduct. The court of appeals reversed Borg's conviction, concluding that the district court erred when it allowed a police officer to testify in the State's case in chief that Borg did not respond to a mailed request for an interview by the officer. At issue on appeal was whether the Fifth Amendment prohibits the State from eliciting testimony during its case in chief regarding a criminal defendant's lack of response to a letter mailed to him by the police when the defendant was not under arrest or in custody and had not been informed of his Miranda rights. The Supreme Court reversed, holding that the district court did not err when it allowed the testimony because the Fifth Amendment does not prohibit the State from introducing evidence regarding a defendant's silence unless the government compelled the defendant to speak or to remain silent. View "State v. Borg" on Justia Law

Appellant Thomas Zais was charged, in part, with disorderly conduct. Before trial, Zais moved to exclude the proposed testimony of his wife on the ground that it was barred by the marital privilege. The district court concluded that the crime exception to the marital privilege did not apply to the charged offense of disorderly conduct, and therefore Zais's wife was barred from testifying against Zais without his consent. The court of appeals reversed and remanded. The Supreme Court affirmed, holding that Zais's wife could testify against Zais on the disorderly conduct charge because (1) the crime exception to the marital privilege applies to the charged offense of disorderly conduct when the alleged conduct is committed by one spouse against the other spouse; and (2) because the conduct underlying Zais's charged offense was directed at his wife, the crime exception to the marital privilege applied in this case. View "State v. Zais" on Justia Law

Appellant Erik Jeffries pled guilty to felony domestic assault and negotiated an agreement with the State in which he would receive a stayed sentence. The district court indicated at the plea hearing that it was accepting Jeffries' plea and that Jeffries was convicted. At a later date, the court told Jeffries it was "giving you your pleas back" and set the case for trial. Jeffries subsequently reached another plea agreement with the State that resulted in a sixty-month executed sentence. Jeffries appealed, arguing that the Double Jeopardy Clause prohibited the State from prosecuting him a second time for felony domestic assault. The court of appeals affirmed the sentence. The Supreme Court reversed and vacated Jeffries' second conviction, holding (1) the district court unconditionally accepted Jeffries' first guilty plea, (2) the guilty plea was recorded as required by statute by its inclusion in the record of the plea hearing, (3) the second prosecution for the same offense violated the Double Jeopardy Clause, and (4) Jeffries did not forfeit his double-jeopardy claim by entering a second guilty plea. Remanded for resentencing on Jeffries' first conviction. View "State v. Jeffries" on Justia Law

Appellant Calvin Ferguson was convicted of first-degree premeditated murder and sentenced to life in prison without any possibility of parole. On appeal, the Supreme Court reversed, holding that the district court erred when it excluded evidence that had an inherent tendency to connect an alternative perpetrator to the shooting of the victim because (1) the evidence showed that the alternative perpetrator's physical description was in several ways similar to the description of the shooter, (2) the alternative perpetrator's vehicle matched the description of the shooter's vehicle, (3) the alternative perpetrator's nickname matched that of the shooter, and (4) the alternative perpetrator had a connection with the victim. Because the district court's exclusion of the alternative perpetrator evidence denied Ferguson his constitutional right to present a complete defense and the court's error was not harmless beyond a reasonable doubt, the case was remanded for a new trial. View "State v. Ferguson" on Justia Law

Appellant Mahdi Ali was indicted for murder in the first degree and murder in the second degree for the shooting deaths of three individuals. The indictment alleged that Ali was seventeen years old on the date of the alleged offenses and therefore automatically subject to trial in the district court. Ali moved to dismiss the indictment, contending that he was fifteen years old on the date of the shootings and that the jurisdiction of the juvenile court was therefore exclusive. The district court denied the motion, concluding that Ali had reached his sixteenth birthday before the date of the shootings. The court of appeals dismissed Ali's appeal, concluding that the district court's order denying Ali's motion to dismiss the indictment was not appealable. The Supreme Court reversed in part and affirmed in part, holding (1) the denial of a defendant's motion to dismiss an indictment for murder for lack of subject matter jurisdiction is immediately appealable as of right; and (2) when the age of the defendant determines the jurisdiction of the court, the State has the burden of proving, by a preponderance of the evidence, the defendant's age on the date of the alleged offense. View "State v. Ali" on Justia Law