Justia Minnesota Supreme Court Opinion Summaries

After a jury trial, the district court convicted Ronald Hill of first-degree premeditated murder. The Supreme Court affirmed Hill's conviction, holding (1) because the district court properly and carefully balanced the potential probative value and prejudicial effects of the proffered impeachment evidence, the court did not abuse its discretion when it admitted evidence of Hill's prior, unspecified felony conviction for impeachment purposes; (2) Hill was not entitled to a new trial because allegedly improper testimony that the State obtained Hill's DNA sample through a search warrant was harmless because it did not affect Hill's substantial rights; (3) any alleged error in admitting evidence that Hill shot the victim with a gun stolen during a home invasion was harmless because there was not a reasonable possibility that the alleged error significantly affected the verdict; and (4) the cumulative effect of any errors resulting from the admission of disputed testimony did not affect Hill's substantial rights, and therefore, Hill was not deprived of his constitutional right to a fair trial. View "State v. Hill" on Justia Law

Elizabeth Hawes was convicted of aiding and abetting her brother, Andrew Hawes, in the first-degree murder of their brother, Edwin Hawes. The district court sentenced Hawes to life imprisonment. The Supreme Court affirmed Hawes' conviction, holding (1) the circumstantial evidence was legally sufficient to support Hawes' conviction of aiding and abetting first-degree premeditated murder; (2) any error the the district court made when it ruled that out-of-court statements made by Andrew were not admissible as declarations against penal interest was harmless beyond a reasonable doubt; and (3) the district court did not abuse its discretion when it denied Hawes' motion for a new trial on the grounds of newly available evidence. View "State v. Hawes" on Justia Law

Samantha Heiges was arrested and charged with second-degree murder and first-degree manslaughter for allegedly drowning her baby daughter in a bathtub immediately after the baby was born. After a jury trial, the district court convicted Heiges of second-degree murder and sentenced her to 299 months in prison. The court of appeals affirmed Heiges's conviction. On review, the Supreme Court affirmed, holding (1) the scope of the term "confession" in Minn. Stat. 634.03 includes statements made to friends and acquaintances after the crime was committed but before the commencement of the police investigation; (2) Heiges's conviction did not violate Section 634.03 when the State established the trustworthiness of Heiges's confessions by presenting sufficient evidence to corroborate the attendant facts and circumstances of those confessions; (3) the facts admitted in Heiges's confession could be used to satisfy Minn. Stat. 634.051, which requires that the evidence that establishes the death of the victim be independent of the evidence that establishes the killing of the victim by the defendant; and (4) the evidence at trial, including Heiges's confessions, was sufficient to sustain Heiges's conviction for second-degree murder. View "State v. Heiges" on Justia Law

Toby Johnson was indicted for intentional murder while committing a kidnapping, murder in the second degree, and kidnapping. Pursuant to a plea agreement, the State amended the first count to aiding and abetting first-degree murder. Johnson then pleaded guilty to counts one and two. Johnson was sentenced to life in prison with a possibility of parole after thirty years. The postconviction court denied Johnson's petition for postconviction relief, and the Supreme Court affirmed. Later, Johnson filed a motion to correct or reduce his sentence, alleging that his guilty plea was invalid for several reasons. The district court concluded that the sentencing court had erred during the sentencing hearing by citing to the second-degree murder statute when imposing a sentence for first-degree murder. As to Johnson's other reasons for requested relief, the court concluded that the Supreme Court's rule from State v. Knaffla barred Johnson from raising claims that were not raised in his first petition for postconviction relief. On appeal, the Supreme Court affirmed the postconviction court's denial of Johnson's motion challenging the validity of his guilty plea, holding that Johnson's petition was untimely and should not be considered on the merits. View "Johnson v. State" on Justia Law

This case involved the assault of a pregnant woman, who, after the assault, received a cesarean section. The baby, named Destiny, later died. After a jury trial, Dameon Gatson was convicted of first-degree premeditated murder for aiding the perpetrator in the killing of Destiny and first-degree assault. On appeal, the Supreme Court affirmed, holding (1) the trial court did not err when it upheld the State's strike of a prospective juror; (2) the evidence was sufficient to support the verdict; (3) the trial court did not err by not instructing the jury on whether Destiny was a "human being" for purposes of the homicide statutes and on whether the removal of Destiny's life support was a superseding intervening cause of her death; (4) any error in admitting portions of the perpetrator's guilty plea was harmless beyond a reasonable doubt and any violation of Gatson's right to confrontation was harmless; (5) Gatson was not entitled to relief on his claim that the admission of the perpetrator's guilty plea violated hearsay rules; and (6) the trial court did not abuse its discretion in denying Gatson's motion for a new trial based on newly discovered evidence. View "State v. Gatson" on Justia Law

John Miles was convicted of first-degree murder. Miles filed a petition for postconviction relief, alleging that he was entitled to a new trial on the basis of newly discovered evidence, specifically, the information in an interview between Miles's counsel and a witness of the homicide, who stated that Miles was not responsible for the shooting of the victim. The postconviction court denied the petition, concluding that it was time-barred under Minn. Stat. 590.01. On review, the Supreme Court affirmed without prejudice, holding (1) the postconviction court erred when it determined that the witness's statement could have been discovered by the exercise of due diligence prior to trial, (2) the postconviction court applied the wrong legal test when it concluded that the witness's statement did not establish by a clear and convincing standard that Miles was innocent, but (3) the court did not err when it denied Miles's petition without a hearing because Miles failed to offer newly discovered evidence with sufficient indicia of reliability to warrant relief under the statute. The Court concluded if Miles could base a new petition on a more satisfactory showing of a genuine statement from the witness, he was entitled to file a new petition. View "Miles v. State" on Justia Law

Appellant Audie Matthews was found guilty by a jury of first-degree murder for a shooting death. When police officers were investigating the shooting, a police dog picked up a "fear scent" near the scene of the shooting and followed the scent through the neighborhood, losing the scent near the location where an officer stopped Matthews for questioning. Matthews appealed, arguing (1) the district court erred in admitting expert testimony that the police dog tracked a fear scent, and (2) the State failed to present sufficient evidence to support his conviction. The Supreme Court affirmed the conviction, holding (1) Matthews failed to establish a reasonable likelihood that the admission of the fear scent testimony significantly affected the verdict under the four factors for harmless error review, and therefore, Matthews was not entitled to a new trial based on the district court's admission of the fear scent testimony; and (2) the alleged shortcomings in the State's evidence did not support a reasonable inference other than that of guilt. View "State v. Matthews" on Justia Law

Gerald Hanson was found guilty by a jury of first- and second-degree controlled substance crime and possession of drug paraphernalia. The cout of appeals reversed, concluding that the evidence was legally insufficient to support Hanson's conviction of first-degree controlled substance crime. At issue on review was whether the evidence that Hansons possessed small, unused bags, when coupled with the remaining evidence as a whole, formed a completed chain that led directly to Hanson's guilt of possessing more than ten grams of methamphetamine with intent to sell as to exclude beyond a reasonable doubt any rational inference other than guilt. On review, the Supreme Court reversed the judgment of the court of appeals, concluding that the evidence presented, when viewed as a whole, was sufficient to support Hanson's first-degree controlled substance crime conviction. View "State v. Hanson " on Justia Law

Daniel Dalbec was found guilty of third-degree criminal sexual conduct. At Dalbec's trial, counsel for the State and Dalbec agreed to submit written closing arguments to the trial court, but defense counsel failed to submit a closing argument. On appeal, Delbec argued that he was entitled to a new trial based on a structural error that allegedly occurred when the trial court adjudicated his guilt without having received a closing argument from his counsel. The court of appeals reversed Dalbec's conviction and granted Dalbec a new trial based on the structural error. The Supreme Court granted the State's petition for review and reversed the court of appeals. At issue was whether defense counsel's failure to submit a written closing argument constituted structural error requiring automatic reversal and a new trial. The Court held (1) defense counsel's failure to submit a closing argument did not result in structural error, and (2) the trial court's adjudication of Dalbec's guilt without the benefit of closing argument was not structural error. Remanded. View "State v. Dalbec" on Justia Law

After Walter Randolph was convicted for misdemeanor domestic assault, the district court issued an order appointing private counsel to represent Randolph on appeal and required Rice County to cover the cost of appointed private counsel. The County objected to the order. The district court ordered a hearing to determine which entity had responsibility for Randolph's representation on appeal and joined intervenors Rice County and the State Board of Public Defense to the action. After a hearing, the district court (1) vacated the previous order; (2) ordered the State or District Public Defender's Office to either substitute one of its attorneys for the appointed private counsel or to pay appointed counsel reasonable attorneys fees; and (3) ordered the State Public Defender's Office to pay transcript costs. The Supreme Court granted the Board's petition for accelerated review and (1) reversed the district court's order appointing the public defender after finding that the legislature had not authorized public defenders to represent indigent misdemeanants on appeal; (2) reversed the district court's order that the State Public Defender's office pay for any required transcripts; (3) reinstated the earlier order appointing private counsel; and (4) ordered the State to cover the cost of appointed counsel. View "State v. Randolph" on Justia Law