Justia Minnesota Supreme Court Opinion Summaries

In each of three separate incidents, the State charged Defendant with two counts of first-degree driving while impaired. Defendant moved to suppress the results of blood and urine tests in each case because law enforcement officers took the samples without a warrant. The district courts denied Defendant's request to suppress the test results, concluding (1) the evanescent quality of alcohol in Defendant's body created exigent circumstances that excused police from seeking a warrant to obtain the urine tests; and (2) Defendant consented to the blood test. The district courts subsequently convicted Defendant of first-degree driving while impaired. The Supreme Court vacated the judgments and remanded for further consideration in light of Missouri v. McNeely. Following remand, the court of appeals reinstated Defendant's appeals. The Supreme Court affirmed Defendant's convictions, holding that, based on the totality of the circumstances, Defendant consented to the search, and therefore, police did not need a warrant to search Defendant's blood or urine. View "State v. Brooks" on Justia Law

Respondent was charged with criminal sexual conduct in the fourth and fifth degree. Respondent agreed to conduct a trial on stipulated facts pursuant to Minn. R. Crim. P. 26.01(3) and waived all trial rights. The district court found Respondent guilty of criminal sexual conduct in the fifth degree. Respondent subsequently filed a petition for postconviction relief, contending that he was entitled to a new trial because the procedure used to convict him was not a trial on stipulated facts pursuant to Rule 26.01(3) and because he received ineffective assistance of counsel. The court of appeals reversed Respondent's conviction on the grounds that Respondent's trial counsel failed to subject the prosecution's case to meaningful adversarial testing. The Supreme Court reversed, holding (1) it was not error for the parties to conduct a bench trial consistent with the provisions of Rule 26.01(2) even though the parties characterized the trial as a stipulated-facts trial under Rule 26.01(3); and (2) Respondent received ineffective assistance of counsel where defense counsel did not entirely fail to subject the prosecution's case to meaningful adversarial testing. View "Dereje v. State" on Justia Law

After a jury trial, Appellant was convicted of two counts of aggravated forgery. The district court sentenced Appellant to twelve months in prison for each charge, to be served concurrently. Appellant appealed, challenging his convictions and sentence. Five days later, Appellant died. Appellant's counsel subsequently filed a motion to abate the prosecution ab initio. The court of appeals denied the motion and dismissed Appellant's direct appeal after deciding against adopting the abatement ab initio doctrine. The Supreme Court reversed the court of appeals' denial of the abatement motion and vacated Appellant's convictions, holding that when a defendant has taken an appeal from a final judgment of conviction in which no restitution was awarded and the accused is deprived of a decision on the merits because of his death, the prosecution should be abated ab initio. Remanded. View "State v. Burrell" on Justia Law

Following a court trial, Appellant was convicted of first-degree criminal sexual conduct, second-degree criminal sexual conduct, kidnapping, and third-degree assault. Upon sentencing Appellant, the district court found that Appellant met the requirements of Minn. Stat. 609.3455(2)(a), which provides for mandatory life imprisonment without the possibility of release for certain aggravated sex crimes, and sentenced Appellant to life imprisonment without the possibility of release on the charge of second-degree criminal sexual conduct. The court of appeals affirmed. Appellant appealed, contending, among other things, that section 609.3455 as applied imposed cruel and unusual punishment in violation of the federal and state constitutions. The Supreme Court affirmed, holding that the imposition of life imprisonment without the possibility of release was not cruel or unusual punishment for Appellant's aggravated criminal sexual conduct. View "State v. Juarez" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder in the course of a burglary and sentenced to life imprisonment. Appellant subsequently filed a petition for postconviction relief, alleging that he was entitled to a new trial based on newly discovered evidence. Specifically, Appellant alleged that Tracy Sailor, one of the people who was with Appellant at the time of the murder, had made statements indicating that Sailor killed the victim and that Sailor's statements were both newly discovered evidence that Sailor was the victim's killer and a recantation of Sailor's trial testimony that Appellant killed the victim. The postconviction court denied Appellant a new trial. The Supreme Court affirmed, holding that the postconviction court did not abuse its discretion by denying Appellant a new trial. View "Torres v. State " on Justia Law

After a jury trial, Appellant was convicted of first-degree murder. The Supreme Court affirmed. Appellant subsequently filed a petition for postconviction relief, alleging, inter alia, that one of the witnesses who testified at Appellant's trial had given false testimony. The postconviction court denied the petition without an evidentiary hearing. The Supreme Court reversed and remanded for a hearing. After an evidentiary hearing on remand, the postconviction court again denied the petition, concluding that Appellant was not entitled to a new trial under the Larrison v. United States test. The Supreme Court affirmed, holding the postconviction court did not abuse its discretion when (1) it concluded that certain out-of-court statements by the witness were inadmissible hearsay; and (2) it denied Appellant's request for the appointment of advisory counsel to assist him at his postconviction evidentiary hearing. View "Dobbins v. State" on Justia Law

Respondent pleaded guilty to second-degree burglary and was placed on probation for five years. The district court also ordered Respondent to pay restitution in monthly payments. Near the expiration of Respondent's probation term, Respondent still owed $20,894 in restitution even though she had complied with the district court's payment schedule. After a hearing, the district court extended Respondent's probation for five years to facilitate continued payment of restitution. Respondent moved to amend the district court's order by reducing the extension to one year, arguing that the district court lacked the authority to extend her probation for five years because Minn. Stat. 609.135(2)(g) authorizes only two one-year extensions of probation based on the failure to pay restitution. The district court agreed and amended the extension of probation from five years to one year. The court of appeals affirmed. The Supreme Court reversed, holding that Minn. Stat. 609.135(1)(a) and Minn. Stat. 609.14 grant a district court authority to extend a term of probation up to the statutory maximum based on a defendant's failure to pay restitution by the end of the originally imposed probation term. Remanded. View "State v. Barrientos" on Justia Law

Appellant was a real estate firm that owned a vacant four-story building (the property) and sought to develop it into an office building. Before the Minneapolis City Council approved Appellant's site plan application, the Minneapolis Heritage Preservation Commission (Commission) nominated the property for designation as a local historic landmark. Appellant subsequently submitted an application for a certificate of appropriateness to the Commission. The City Council denied the application and subsequently designated the property as a local historic landmark. Plaintiff commenced this action against the City, alleging that the City violated Minn. Stat. 15.99(2)(a) by failing to approve or deny the application for a certificate of appropriateness within sixty days. The district court granted summary judgment for the City, concluding that section 15.99(2)(a) did not apply to an application for a certificate of appropriateness. The court of appeals affirmed. The Supreme Court reversed, holding that an application for a certificate of appropriateness is a "written request relating to zoning" under section 15.99(2)(a), and because the City failed to approve or deny Appellant's application within sixty days, summary judgment for the City was not proper. Remanded. View "500, LLC v. City of Minneapolis" on Justia Law

In 2009, Minnesota Power sought an increase in service rates of approximately 18.9 percent. As part of its submission to the Minnesota Public Utilities Commission, Minnesota Power also requested an interim rate increase of approximately $73.3 million. The Commission decided to set the interim rate increase at approximately $48.5 million after finding exigent circumstances existed. The court of appeals affirmed, concluding that the Commission did not err in finding exigent circumstances and did not abuse its discretion in setting interim rates. The Supreme Court affirmed, holding that substantial evidence supported the Commission's decision to set Minnesota Power's interim rate increase at $48.5 million. View "In re Application of Minn. Power for Auth. to Increase Rates for Elec. Serv. in Minn." on Justia Law

On June 6, 2013, the Green Party of Minnesota and its chair, Brian Begin, filed a petition asserting that Respondent Secretary of State Mark Ritchie erred in decertifying the Green Party as a minor political party. Petitioners sought an order from the Supreme Court to direct the Secretary to correct his alleged error by restoring the Green Party’s minor political party status as of January 1, 2013. Because the Supreme Court concluded that the Green Party’s claims fell outside the scope of the applicable statute. As such, the Court dismissed the petition. View "Begin vs. Ritchie" on Justia Law