Justia Minnesota Supreme Court Opinion Summaries

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

Steven Leathers was convicted of five counts of first-degree assault against a peace officer pursuant to Minn. Stat. 609.221, 2(a). The district court sentenced Leathers to concurrent sentences totaling 189 months with eligibility for supervised release after 126 months in prison, or two-thirds of his sentence. Leathers appealed his conviction, and the State appealed the sentence. The court of appeals upheld Leathers' conviction but reversed the sentence, holding that Leathers was not eligible for supervised release. The Supreme Court granted review on the issue of supervised release. The Court reversed the court of appeals and affirmed the district court's decision, holding that the definition of the phrase "full term of imprisonment" in section 609.221, 2(b) means two-thirds of a defendant's executed prison sentence. Thus, Leathers was ineligible for work release or supervised release until he had served a full two-thirds of his sentence, after which point he would be eligible for supervised release. View "State v. Leathers" on Justia Law

Two tribal members (Appellants) were committed as sexually dangerous persons under Minn. Stat. 253B.02, 18c and committed to the Minnesota Sex Offender Program. Appellants moved to dismiss their commitments for lack of subject matter jurisdiction based on their status as enrolled tribal members. The district court denied both motions to dismiss. Appellants appealed the district court's orders, and the court of appeals affirmed, holding that even though federal law did not affirmatively grant the State jurisdiction to commit appellants, federal law did not preempt appellants' commitments. On review, the Supreme Court affirmed, holding that (1) based on the terms of the state's civil commitment statute, appellants' commitments were civil causes of action subject to Congress' express grant of civil jurisdiction under 28 U.S.C. 1360(a); (2) in light of the strong State interests presented, the fact that Congress has not pervasively regulated this area of the law, and the minimal intrusion on tribal sovereignty, Minnesota's enforcement of chapter 253B was not preempted; and (3) the state had jurisdiction to civilly commit Appellants. View "In re Civil Commitment of Johnson" on Justia Law

Appellant Andy Prtine was convicted of first-degree felony murder for the stabbing death of Brent Ward. On appeal, Appellant argued that he was denied effective assistance of counsel because his attorney conceded in his closing argument without Appellant's consent that Appellant intended to kill Ward. The Supreme Court held that Appellant's counsel conceded guilt with respect to the element of intent to kill in his statement and remanded to the district court to determine whether Appellant acquiesced in his trial counsel's concession of intent to kill. The district court ruled that Appellant acquiesced in his counsel's concession that the killing was intentional. The Supreme Court affirmed Appellant's conviction, holding that (1) Appellant acquiesced in the concession, and (2) because Appellant acquiesced in his trial counsel's concession of guilt with respect to intent to kill, Appellant was not entitled to a new trial based on his ineffective-assistance-of-counsel claim. View "State v. Prtine" on Justia Law

After a jury trial, Jack Nissalke was convicted of first-degree premeditated murder and sentenced to life imprisonment. On appeal, the Supreme Court affirmed, holding (1) Nissalke was not entitled to a new trial based on the district court's entry into the jury room and communication with the jury outside the presence of counsel and Nissalke while the jury was deliberating; (2) the district court did not violate Nissalke's right to present a complete defense by refusing to admit certain alternative perpetrator evidence; (3) the State did not commit prejudicial misconduct by asserting facts not in evidence in opening statements and closing arguments and by shifting the burden of proof to Nissalke in closing; (4) although the district court erred by failing to remove a biased juror for cause, this error did not require reversal; (5) the evidence was sufficient to support Nissalke's conviction; (6) the State did not violate Nissalke's due process rights by failing to preserve physical evidence; and (7) Nissalke was not entitled to a new trial based on his claims of ineffective assistance of counsel. View "State v. Nissalke" on Justia Law