Justia Minnesota Supreme Court Opinion SummariesArticles Posted in Juvenile Law
Roberts v. State
The Supreme Court affirmed the judgment of the court of appeals affirming the district court's denial of Defendant's petition for postconviction relief, holding that, under Minn. Stat. 260B.245, subd. 1(b), delinquency adjudications may be deemed "felony convictions" for the purpose of the statutory definition of a crime of violence.Defendant was charged with possession of a firearm by an ineligible person, which required proof that Defendant had been convicted of a crime of violence. Defendant pled guilty to the offense, admitting that he had been adjudicated delinquent for committing fifth-degree possession of a controlled substance. The district court accepted the plea and placed Defendant on probation. Defendant later filed a petition for postconviction relief, asserting that his juvenile delinquency adjudication failed to satisfy the definition of a "crime of violence" because, under section 260B.245, a delinquency adjudication cannot be deemed a "conviction of crime." The district court denied postconviction relief. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the phrase "felony convictions," as used in the statutory definition of crime of violence, includes a juvenile delinquency adjudication for felony-level offenses listed in Minn. Stat. 624.712, subd. 5; and (2) Defendant provided an adequate factual basis for his guilty plea. View "Roberts v. State" on Justia Law
In re A.J.B.
The Supreme Court reversed the decision of the court of appeals concluding that two Minnesota statutes - Minn. Stat. 609.749, subd. 2(6), the stalking-by-mail provision, and Minn. Stat. 609.795, subd. 1(3), the mail-harassment statute - are constitutional under the First Amendment, holding that both statutes are facially overbroad.A.J.B. was found guilty of gross-misdemeanor stalking by use of the mail, misdemeanor harassment by use of the mail, and felony stalking. The court of appeals affirmed A.J.B.'s adjudications for stalking by mail and mail harassment, thus rejecting his constitutional challenges. On appeal, A.J.B. argued that his adjudications under the stalking-by-mail provision and mail-harassment statute must be vacated as contravening the First Amendment. The Supreme Court held (1) section 609.749, subd. 2(6), is facially overbroad and not subject to either a narrowing construction or severance of unconstitutional provisions; (2) section 609.795, subd. 1(3), is facially overbroad, but the statute can be saved through severance of the constitutionally problematic language; and (3) because it is unclear whether Defendant's adjudication of delinquency for mail-harassment is based on the severed language, Defendant's adjudication under section 609.795, subd. 1(3), is reversed and the case remanded. View "In re A.J.B." on Justia Law
Flowers v. State
The Supreme Court reversed Defendant’s two concurrent life sentences with the possibility of release after thirty years, holding that neither Miller v. Alabama, 567 U.S. 460 (2012), nor Jackson v. State, 883 N.W.2d 272 (Minn. 2016), limited the district court’s authority to impose consecutive sentences in this case.The district court convicted Defendant, a juvenile at the time of his offense, of two counts of first-degree premeditated murder and sentenced him to two consecutive life terms of imprisonment without the possibility of release. Defendant later petitioned for postconviction relief, arguing in part that the court’s authority to impose consecutive life sentences with the possibility of release after thirty years was limited by both Miller and Jackson. The district court granted the petition and imposed two concurrent life sentences with the possibility of release after thirty years. The Supreme Court reversed and remanded for resentencing, holding that the district court mistakenly believed that Miller and Jackson limited its authority to impose consecutive sentences in this case. View "Flowers v. State" on Justia Law
In re Welfare of C.J.H.
The State filed a juvenile delinquency petition against seventeen-year-old C.J.H. Defense counsel at the first appearance told the juvenile court that the parties had agreed to a “continuance for dismissal.” Without finding that the allegations in the charging document had been proved, the juvenile court continued the delinquency proceeding and, approximately nine months later, terminated the continuance. The juvenile court subsequently adjudicated C.J.H. delinquent. C.J.H. appealed, arguing that the proceedings at the first appearance constituted a “continuance without adjudication” because he unconditionally admitted the charged offense. Therefore, C.J.H. argued, under Minn. R. Juv. Delinq. P. 15.05, the juvenile court’s jurisdiction expired before he was adjudicated delinquent. The court of appeals reversed, concluding that the juvenile court’s jurisdiction expired before C.J.H. was adjudicated delinquent. The Supreme Court reversed, holding (1) the plain language of Rule 15.05 requires a juvenile court to find the allegations in the charging document to have been proven before continuing the case without adjudication; and (2) because no such finding was made in this case, the proceedings at C.J.H.’s first appearance did not constitute a continuance without adjudication. View "In re Welfare of C.J.H." on Justia Law
Posted in: Juvenile Law
Roman Nose v. State
In 2001, Respondent was found guilty of first-degree murder while committing or attempting to commit criminal sexual conduct and first-degree premeditated murder. Respondent was a juvenile when he committed the crime. The district court sentenced Respondent to life without the possibility of release (LWOR) under the mandatory sentencing scheme in Minn. Stat. 609.106(2)(1). After the U.S. Supreme Court decided Miller v. Alabama in 2012, Respondent filed a petition for postconviction relief, arguing that his sentence violated the Eighth Amendment. The postconviction court granted Respondent’s petition and resentenced him to life in prison with the possibility of release after thirty years. The Minnesota Supreme Court subsequently issued its decision in Chambers v. State, which held that the Miller rule does not apply retroactively to a juvenile whose sentence of LWOR under section 609.106(2)(1) became final before the Miller rule was announced. Thereafter, in the instant case, the Supreme Court reversed the postconviction court’s order and reinstated the original sentence of LWOR, holding that the postconviction court’s legal conclusion was in direct conflict with Chambers, and the circumstances of this case did not warrant granting relief to Respondent under the Court’s supervisory powers to ensure the fair administration of justice. View "Roman Nose v. State" on Justia Law
In re Welfare of B.A.H.
B.A.H. was charged with first-degree criminal sexual conduct under Minn. Stat. 609.342(1)(g) for acts he committed with his cousin, then age thirteen, when B.A.H. was age fourteen. After a bench trial on stipulated evidence, the district court found B.A.H. guilty of the charge and adjudicated him delinquent. The court of appeals reversed, holding that subdivision (1)(g) violated B.A.H.’s constitutional rights to due process and equal protection. The Supreme Court reversed, holding that B.A.H.’s deliquency adjudication did not violate his constitutional rights to due process and equal protection, as (1) subdivision (1)(g) was not unconstitutionally vague; and (2) the State’s reasons for charging B.A.H. and not his cousin were rational, and therefore, constitutional. View "In re Welfare of B.A.H." on Justia Law
Posted in: Juvenile Law
In re Welfare of J.H.
Respondent was charged by juvenile petition, as both a principal and an accomplice, with criminal sexual conduct and other crimes arising out of the rape of a fourteen-year-old girl. After a hearing, the juvenile court concluded that Respondent had not overcome the presumption in favor of certification to adult court and certified Respondent for prosecution as an adult. The court of appeals reversed, concluding that the juvenile court abused its discretion by failing to expressly weigh the seriousness of the alleged offense and Respondent’s prior record of delinquency separate from other public safety factors and by failing to specifically delineate how its determination of the two factors impacted its certification decision, as required by Minn. Stat. 260B.125. The Supreme Court reversed, holding (1) the court of appeals erroneously interpreted section 260B.125(4); and (2) the juvenile court did not abuse its discretion by concluding that Respondent failed to overcome the presumption in favor of certification. View "In re Welfare of J.H." on Justia Law
In re J.J.P.
Respondent was adjudicated delinquent of felony burglary and misdemeanor theft. Thereafter, Respondent obtained a district court order expunging his juvenile delinquency records held by the judicial branch and sought to expunge his juvenile delinquency records held by the executive branch. The district court denied the request, but the court of appeals reversed. The Supreme Court affirmed in part, reversed in part, and remanded, holding (1) under Minn. Stat. 260B.198(6), the authority of the district court to expunge juvenile delinquency records in executive branch files is limited to the order adjudicating the juvenile delinquent; (2) to determine whether expungement is advisable within the meaning of section 260B.198(6), the district court must weight the benefit to the petitioner against the detriment to the public and the burden on the court; and (3) the district court should decide if Respondent's petition merits expungement by applying the balancing test the Court articulated here to the specific facts and circumstances of the case. View "In re J.J.P." on Justia Law
State v. Grigsby
The State filed a delinquency petition against Appellant, alleging that Appellant committed second-degree intentional murder. The juvenile court certified the proceeding to adult court. Appellant was charged in district court with second-degree intentional murder. The complaint was amended to include second-degree felony murder. The jury found Appellant guilty of second-degree felony murder and second-degree manslaughter. Appellant appealed, arguing that the district court lacked subject-matter jurisdiction over the amended charge of second-degree felony murder and the lesser-included offense of second-degree manslaughter. The court of appeals affirmed, holding (1) the district court had jurisdiction over the charge specified in the certification order and other charges arising out of the same behavioral incident; and (2) the certification process did not violate Appellant's right to procedural due process. The Supreme Court affirmed, holding (1) a "proceeding" permitted by statute includes non-enumerated offenses arising out of the same behavioral incident as the offense enumerated in the certification order; and (2) following a valid certification order, a child no longer has a liberty interest in a juvenile adjudication for offenses arising out of the behavioral incident certified to adult court, and therefore the district court is not required to conduct another hearing on the certification issue. View "State v. Grigsby" on Justia Law
In re M.L.M.
Appellant, a juvenile, was petitioned for a felony and then adjudicated delinquent of a misdemeanor arising out of the same set of circumstances. The court ordered that Appellant provide a biological speciman to determine her DNA profile for the limited purpose of criminal identification after concluding that Minn. Stat. 609.117, subd. 1(2), which requires a juvenile adjudicated delinquent of a misdemeanor to submit a DNA sample, did not violate constitutional prohibitions against unreasonable searches and seizures and was not a denial of equal protection. The Supreme Court affirmed after applying a totality-of-the-circumstances test, holding (1) the State's legitimate governmental interests in collecting Appellant's DNA outweighed Appellant's reduced expectation of privacy following her misdemeanor adjudication arising out of the same set of circumstances as her felony petition; (2) consequently, as applied to Appellant, section 609.177, sub. 1(2) did not violate the prohibitions against unreasonable searches and seizures in the state and federal constitutions; and (3) Appellant's equal protection claim failed because Appellant was not similarly situated to misdemeanants without a felony petition, who were not required to provide a DNA sample under the statute. View "In re M.L.M." on Justia Law