Justia Minnesota Supreme Court Opinion Summaries

After a jury trial, appellant Justin Buckingham was convicted of attempted first-degree premeditated murder and attempted first-degree drive-by-shooting murder. The Supreme Court affirmed appellant's convictions but modified his sentence. Appellant subsequently filed a petition for postconviction relief, asserting that the district court admitted his statements to police in violation of his constitutional rights, his court-ordered psychological evaluation was incomplete, the district court gave the jury an erroneous accomplice liability instruction, and his trial counsel was ineffective. The district court denied Buckingham's petition for relief without a hearing, rejected Buckingham's claims on the merits, and held that most of Buckingham's claims were procedurally barred under State v. Knaffla. The Supreme Court affirmed, holding the district court did not abuse its discretion when (1) it held that Buckingham's claims were barred under Knaffla, and (2) it denied appellant an evidentiary hearing because the records of the proceeding conclusively showed that Buckingham was not entitled to postconviction relief. View "Buckingham v. State" on Justia Law

Appellant Clemmie Tucker pleaded guilty to second-degree unintentional felony murder. Under the terms of the plea agreement, the district court sentenced Tucker to 225 months in prison. The sentence represented an upward durational departure from the presumptive sentencing range of 128 to 180 months for a defendant convicted of second-degree unintentional murder with Tucker's criminal history score. Tucker filed a petition for postconviction relief in which he claimed the sentencing court abused its discretion when it imposed an upward departure based on particular cruelty to his victim. The court of appeals affirmed the denial of postconviction relief on the ground that Tucker's failure to render aid to his victim constituted particular cruelty. On review, the Supreme Court reversed, holding that the sentencing court's reason for departure was improper. Permitting an upward departure under the circumstances of the case failed to apply the plain meaning of the phrase "particular cruelty" and disregarded the fundamental requirement permitting sentencing departures only when a defendant's conduct in the commission of an offense is significantly more serious than that typically involved in the commission of the offense in question. Remanded. View "Tucker v. State" on Justia Law

Diane Cox was charged with issuing dishonored checks with a value of more than $500 in violation of the dishonored-check statute, which is a felony. Cox filed a motion to dismiss, arguing that the sentencing disparity between the dishonored-check statute and the theft-by-check statute violated her constitutional right to equal protection of the law because issuing a dishonored check is a lesser-included offense of theft-by-check yet is punished more harshly than the greater offense. The district court denied Cox's motion but certified to the court of appeals the question of whether the disparity in the severity of punishment between the two statutes, which arguably contemplate the same acts committed under the same circumstances by persons in like situations, constitutes an equal protection violation as applied to defendant and those similarly charged. The appellate court answered the question in the negative. The Supreme Court affirmed, holding that Cox is not similarly situated to a defendant who commits theft by check because her conduct would not support a conviction for theft by check, and therefore Cox was not denied equal protection of the law. View "State v. Cox" on Justia Law

Appellant John Koppi was convicted of second-degree refusal to submit to chemical testing. Under state laws, refusing a chemical test is not a crime unless an officer had probable cause to believe the person was operating a motor vehicle while impaired. Koppi appealed, arguing that the district court abused its discretion in giving the jury an erroneous instruction that articulated a purely subjective definition of probable cause. The court of appeals affirmed. The Supreme Court found because the jury instruction did not require the jury (1) to evaluate probable cause based on the totality of the facts and circumstances and (2) to determine whether a reasonable police officer would find probable cause, the instruction did not articulate a correct, objective standard of probable cause. The Court held Koppi was entitled to a new trial because the erroneous jury instruction was not harmless beyond a reasonable doubt. The Court also held that Koppi waived his second argument because Koppi failed to properly preserve it. Reversed and remanded. View "State v. Koppi" on Justia Law

In district court, appellant was convicted of aiding and abetting first-degree premeditated murder. At issue was whether the district court erred when it denied appellantâs pretrial motion to suppress statements made to law enforcement officials after appellant allegedly invoked his state and federal constitutional rights to remain silent and to have counsel present during custodial interrogation. The Supreme Court affirmed, holding (1) an invocation of the right to remain silent is ambiguous if the suspectâs statement could be interpreted as either a general refusal to answer any questions or as an expression of unwillingness to discuss a specific topic, and (2) when a suspect makes an equivocal invocation of the right to counsel, providing the suspect with a Miranda warning is sufficient as a matter of law to satisfy Minnesotaâs âstop and clarifyâ rule.

Appellant Dario Bonga pled guilty to first-degree premeditated murder less than one day after he confessed to killing Carlos San Miguel and attempted to kill himself while in custody awaiting trial. The district court accepted Appellantâs guilty plea, convicted him, and sentenced him to life in prison. Appellant filed a petition for post conviction relief in which he sought to withdraw his guilty plea, arguing that he was not competent to plead guilty. On appeal to the Supreme Court, Appellant argued that the district court did not give sufficient weight to evidence that suggested he was incompetent to plead when it sentenced him to life. Particularly, Appellant argued that the court should have ordered an examination and report on Appellantâs mental condition when it learned that Appellant attempted suicide the day before the hearing. The Supreme Courtâs review of the record revealed that on several occasions Appellant was offered counsel, dismissed counsel, sought to speak with the prosecutors, and asked to represent himself at trial. The record would also reveal that the trial court asked Appellant multiple times, on the record, whether he understood the nature of the charges against him and whether Appellant understood the risk he ran by representing himself. The Court was satisfied that the trial court gave Appellant every opportunity to seek counsel and preserve his legal rights. Finding no error, the Supreme Court affirmed Appellantâs conviction and sentence.

The issue for the Supreme Court to resolve in this case stems from the arrest of Appellant Brian Hester. Appellant was arrested by a Lower Sioux Indian Community Police officer on DWI charges. The temperature was between 10 and 15 degrees below zero at the time the Lower Sioux officer stopped Appellant. Appellant was transferred to a local jail for further tests to determine the level of Appellantâs impairment. After completing the field sobriety tests at the jail, the officer placed Appellant under arrest. Appellant was advised that refusing to submit to further testing would constitute a crime. Appellant refused and was charged with first-degree driving while impaired, and first-degree test refusal. A jury found Appellant guilty of only the test-refusal charge. Appellant sought to vacate the judgment, claiming that the arresting officer was not a âpeace officerâ as defined by state law. Appellate courts found that the officer was indeed a police officer, and had the authority to require Appellant to take the subsequent tests. On further review, the Supreme Court found that the Lower Sioux were not in compliance with state law requiring them to carry the correct liability insurance limits at the time Appellant was arrested. The lack of liability insurance undermined the officerâs authority to request that Appellant take the subsequent chemical tests. Accordingly, the Supreme Court vacated Appellantâs conviction for criminal test refusal.

A Hennepin County grand jury indicted Appellant Gary Vue with several gang-related felonies. A jury found Appellant guilty, and the district court convicted him and imposed a life sentence with the possibility of parole after 31 years. Appellant appealed his conviction, claiming that the district court erroneously admitted his statement to the police, and that the evidence presented at trial was insufficient to convict him. In December, 2005, police received a tip on the whereabouts of Appellant and his brother who were both suspects in the shooting death of Za Xiong. The tip lead police to Appellant then living in Sacramento, California. The police went to Sacramento to interview him. Within eight minutes, Appellant confessed to the shooting. Police did not believe they had the authority to arrest Appellant outside their jurisdiction. They returned to Hennepin County and got an arrest warrant for the brother. Three years later, in March, 2009, police were able to apprehend Appellant in St. Paul. Appellant pled not guilty, and sought to exclude his statements made to police while in Sacramento. The district court denied Appellantâs motion to suppress, concluding that Appellant was not in custody and, therefore, the police were not required legally to advise him of his Miranda rights. The Supreme Court held that the lower court was correct to deny Appellantâs motion to suppress his statement to the police in Sacramento. Furthermore, it found that the evidence presented at trial was sufficient to allow a rational trier of fact to convict him of the gang-related felonies. The Court accordingly affirmed Appellantâs conviction.