Justia Minnesota Supreme Court Opinion Summaries

In this sexual assault case, the Supreme Court granted a writ of prohibition sought by Hope Coalition to prohibit the district court from requiring it to disclose records concerning the alleged victim's counseling to the district court for in camera review, holding that the district court's actions were unreasonable.Hope Coalition invoked the sexual-assault-counselor privilege under Minn. Stat. 595.02, subdivision 1(k) to prevent Defendant's motion in his criminal prosecution seeking disclosure of records concerning the alleged victim's counseling. The district court concluded that compliance with the subpoena to produce the records protected by the sexual-assault-counselor privilege for in camera review was reasonable without addressing that privilege. The Supreme Court reversed, holding (1) the plain language of the statute creates a privilege for sexual assault counselors that cannot be pierced in a criminal proceeding without the victim's consent; and (2) the district court's denial of Hope Coalition's motion to quash the subpoena seeking the records at issue was unauthorized by law. View "State v. Conrad" on Justia Law

The Supreme Court affirmed Defendant's sentence for aiding an offender as an accomplice after the fact for her role in concealing evidence of a murder that her husband committed, holding that the sentence did not exceed the statutory maximum.Defendant pleaded guilty to aiding an offender to avoid arrest and being an accomplice after the fact. After a sentencing hearing, the district court sentenced Defendant to forty-eight months in prison. The Supreme Court affirmed, holding that the district court did not err in sentencing Defendant to forty-eight months in prison for being an accomplice after the fact. View "State v. Miller" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing the decision of the district court to deny Defendant's motion to withdraw his guilty plea, holding that Defendant did not meet his burden of proving that his plea was invalid.Defendant pleaded guilty to the charge of violating a domestic abuse no contact order. On appeal, Defendant argued that a manifest injustice occurred that required a plea withdrawal due to his failure personally to admit his previous convictions during his plea colloquy, which made his plea inaccurate. The court of appeals agreed and reversed. The Supreme Court reversed, holding (1) Defendant did not meet his burden to establish a manifest injustice requiring a plea withdrawal or that his plea was otherwise invalid; and (2) therefore, the court of appeals committed reversible error in reversing Defendant's conviction on the basis that his guilty plea was invalid. View "State v. Epps" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree premeditated murder, holding that the State presented sufficient evidence to support the conviction and that the sentence imposed upon Defendant was not unconstitutionally cruel.After a jury trial, Defendant was convicted of first-degree premeditated murder and sentenced to life imprisonment without the possibility of release. The Supreme Court affirmed the conviction and sentence, holding (1) there was sufficient evidence in the record to support the conviction; and (2) a mandatory sentence of life without the possibility of release is not unconstitutionally cruel under Minn. Const. art. I, section 5 when imposed on a twenty-one-year-old defendant who has been convicted of first-degree premeditated murder. View "State v. Hassan" on Justia Law

The Supreme Court affirmed the order of the court of appeals remanding this case to the district court to have two jurors who testified in private during a post-trial Schwartz hearing questioned again in a public hearing, holding that the court of appeals properly concluded that the district court erred when it closed the first part of the Schwartz hearing to the public.After a jury trial, Defendant was found guilty of second-degree murder. Thereafter, one of the jurors suggested that she might have introduced extraneous information during deliberations. The district court held a Schwartz hearing to determine the effect of this information on the verdict but divided the hearing into two parts because of jurors' scheduling conflicts. The court of appeals ruled that the district court erred when it closed the first part of the Schwarz hearing to the public. The Supreme Court affirmed, holding (1) a post-trial Schwartz hearing is more analogous to a pretrial suppression hearing; and (2) the appropriate remedy was to remand to conduct a public Schwartz hearing. View "State v. Jackson" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree felony murder and his sentence of life imprisonment as well as the denial of his petition for postconviction relief, holding that sufficient evidence supported the conviction and that Defendant's constitutional and ineffective assistance of counsel challenges failed.After he was convicted Defendant filed a direct appeal. The Supreme Court stayed the appeal to allow Defendant to pursue postconviction relief. The district court denied the petition following an evidentiary hearing. The Supreme Court lifted the stay, consolidated Defendant's appeal, and affirmed, holding (1) the evidence was sufficient to support the conviction; (2) Defendant's arguments related to a witness's identification testimony failed; (3) Defendant's right to a speedy trial was not violated; and (4) Defendant's claims of ineffective assistance of counsel were without merit. View "State v. Jones" on Justia Law

The Supreme Court affirmed the decision of the court of appeals holding that decisions made under Minn. Stat. 43A.33 are quasi-judicial administrative decisions subject to certiorari review by the court but reversed its holding that the Bureau of Mediation Services was a proper party to the appeal, holding that the Bureau was not a proper party to the certiorari appeal.When the Minnesota Department of Corrections sought certiorari review of an arbitrator's decision granting Appellant's appeal from the discharge of his employment at the Minnesota Department of Corrections, Appellant challenged the court of appeals' jurisdiction to hear the appeal, arguing that review must be undertaken by the district court. The court of appeals upheld the arbitrator's decision. The Supreme Court affirmed in part and reversed in part, holding (1) Appellant and the Department were not parties to an arbitration agreement that invoked the judicial review procedures of the Uniform Arbitration Act; (2) the decision of an arbitrator appointed according to section 43A.33 is a quasi-judicial determination of an inferior tribunal reviewable via writ of certiorari at the court of appeals; and (3) the Bureau was not a proper party to this appeal because it had no legal or equitable interest in the outcome. View "Minn. Department of Corrections v. Knutson" on Justia Law

The Supreme Court affirmed the judgment of the district court denying Appellant's fourth postconviction petition alleging alleging a claim of newly-discovered evidence, holding that the district court did not abuse its discretion.Appellant was convicted of six counts of aiding and abetting first-degree murder for the benefit of a gang and sentenced to life in prison without the possibility of release. In his fourth postconviction petition, Defendant asserted a successive claim of newly discovered evidence based on three affidavits. The district court denied the petition, determining that the claims were time-barred. The Supreme Court affirmed, holding that the district court properly concluded that Appellant's fourth petition for postconviction relief was untimely. View "Caldwell v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court imposing a mandatory five-year conditional release term in connection with Defendant's conviction of fourth-degree assault of a secure treatment facility employee of the Minnesota Sex Offender Treatment Program (MSOP), holding that there was a rational basis for the sentencing disparity at issue in this case.After he was convicted, Defendant filed a petition for postconviction relief arguing that Minn. Stat. 609.2231, subd. 3a(e) required the district court to impose different sentences for the same conduct based on the defendant's civil commitment status, and therefore, his sentence violated his equal protection rights under the United States and Minnesota Constitutions. The district court denied postconviction relief, and the court of appeals affirmed. The Supreme Court affirmed, holding that the disparate sentence survived rational basis review. View "State v. Lee" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the judgment of the district court applying the endangerment standard of the child-custody modification statute, Minn. Stat. 518.18(d)(iv), to a noncustodial parent's motion for joint legal custody of the parties' child based on their prior stipulation to apply the statutory best-interests standard set forth in Minn. Stat. 518.18(d)(i), holding that the district court erred.The noncustodial parent's modification motion in this case was expressly predicated on section 518.18(d)(i), which provides that the statutory best-interests standard set forth at Minn. Stat. 518.17 applies if the parties previously agreed in a court-approved writing to the application of that standard. The district court denied the motion for custody modification without holding an evidentiary hearing. The court of appeals affirmed. The Supreme Court reversed, holding that the district court erred by requiring the noncustodial parent to establish a prima facie case for a change in custody based on the statutory endangerment standard in section 518.18(d)(iv). View "Woolsey v. Woolsey" on Justia Law