Justia Minnesota Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of two counts of first-degree premeditated murder, first-degree arson of a dwelling and theft of a motor vehicle. The Supreme Court affirmed on appeal. Thereafter, Defendant filed a petition for postconviction relief, alleging claims of trial error, ineffective assistance of trial counsel, and ineffective assistance of appellate counsel. The postconviction court denied the petition without granting an evidentiary hearing, concluding that Defendant’s claims were either procedurally barred or meritless. The Supreme Court affirmed, holding (1) Defendant’s claims of trial error were procedurally barred; (2) Defendant’s ineffective assistance of trial counsel claims were either procedurally barred or did not otherwise entitle him to an evidentiary hearing; and (3) Defendant did not receive ineffective assistance of appellate counsel. View "Zornes v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and other crimes. The Supreme Court affirmed on appeal. Defendant later filed a pro se petition for postconviction relief, alleging several claims of error. The postconviction court summarily denied Defendant’s petition as untimely, concluding that the petition was filed beyond the two-year limitations period in Minn. Stat. 590.01(4)(a)(2) and that the petition did not meet any exceptions to the time limit. The Supreme Court affirmed, holding (1) Defendant’s claims challenging the jury instructions were procedurally barred, and Defendant failed to satisfy either Knaffla exception; and (2) Defendant’s claim that his sentence of life imprisonment without the possibility of release is unconstitutional under Miller v. Alabama was without merit. View "Munt v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree felony murder. The district court sentenced Defendant to life in prison. The Supreme Court affirmed the conviction on appeal. Thereafter, Defendant filed a petition for a writ of habeas, asserting many of the same claims he raised on direct appeal. The federal district court dismissed the petition. Defendant appealed. Defendant subsequently filed a petition for postconviction relief, seeking an evidentiary hearing, vacation of his sentence, and/or a new trial based on fifteen claims. The postconviction court summarily denied the petition, ruling that it was procedurally barred under State v. Knaffla. The Supreme Court affirmed, holding that Defendant’s claims were procedurally barred under State v. Knaffla. View "Davis v. State" on Justia Law

After a jury trial, Appellant was found guilty of first-degree murder of a peace officer while the officer was engaged in official duties. Defendant was sentenced to life imprisonment without the possibility of release and ordered to pay restitution to the Crime Victims Reparations Board. Appellant later filed a motion to correct his sentence. The postconviction court denied the motion, concluding that it was untimely under Minn. Stat. 611A. 045(3)(b) because Appellant failed to challenge the restitution award within thirty days of receiving written notice of the amount of restitution requested. The Supreme Court affirmed, holding that the district court did not err in denying Appellant’s motion on the grounds of untimeliness. View "Evans v. State" on Justia Law

Appellant Patrick Figgins brought suit against respondent Grand Rapids State Bank (GRSB) and its CEO, respondent Noah Wilcox, claiming, among other things, that Wilcox and GRSB had made misrepresentations and breached an oral agreement regarding the due date of a payment on an outstanding loan. Respondents moved to dismiss on the ground that Minn. Stat. 513.33 (2014) did not permit these claims. The district court agreed and dismissed the complaint with prejudice. Figgins, on appeal, argued that section 513.33 did not apply to his claims and, to the extent it did, his promissory estoppel claim should have survived because promissory estoppel was an exception to the statute. Finding no reversible error in the district court's judgment, the Minnesota Supreme Court affirmed. View "Figgins vs. Wilcox" on Justia Law

Following a bench trial, a district court found appellant Marcus Barshaw guilty of first-degree premeditated murder in connection with the shooting death of Jeffery Schutz and first-degree assault of a peace officer in connection with an assault committed against Deputy Chad Meemken. The court sentenced Barshaw to life in prison without the possibility of release. On appeal, Barshaw argued that the evidence presented at trial was insufficient to support his convictions of premeditated murder and first-degree assault of a peace officer. Because the evidence was sufficient to support both convictions, the Supreme Court affirmed. View "Minnesota v. Barshaw" on Justia Law

After a jury trial, Defendant was convicted of first-degree premeditated murder on an accomplice-liability theory. The district court sentenced Defendant to life imprisonment without the possibility of release. The Supreme Court affirmed, holding (1) the district court did not err in denying Defendant’s motion to suppress evidence seized as a result of her arrest, as the arrest was supported by probable cause; (2) the district court did not err in overruling Defendant’s challenges to the State’s peremptory strikes of certain jurors under Batson v. Kentucky; (3) the district court did not abuse its discretion when instructing the jury on accomplice liability; and (4) Defendant’s pro se contentions lacked merit. View "State v. Onyelobi" on Justia Law

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, holding (1) the district court did not err when it denied Defendant’s motion to suppress statements from a police interview conducted shortly after the murder; (2) the warrantless seizure of Defendant’s cellphone did not violate her constitutional rights; (3) Defendant was not entitled to relief on her claim that defective search warrants violated her constitutional rights; (4) the district court did not err when it failed to give an accomplice-corroboration jury instruction; (5) the district court did not err in denying Defendant’s request to remove a juror for cause; and (6) the evidence was sufficient to support Defendant’s conviction of first-degree premeditated murder. View "State v. Horst" on Justia Law

Defendant entered a straight plea to the charge of conspiracy to commit a first-degree controlled substance crime. At the plea hearing, Defendant waived his right under Blakely v. Washington to have a jury determine whether aggravating factors existed to justify an upward durational department to his sentence. During Defendant’s Blakely court trial to determine whether the alleged aggravating factors existed, the district court did not apply the Minnesota Rules of Evidence. After the trial, the district court concluded that the State proved all three of the aggravating sentencing factors. The court imposed a 240-month sentence, a greater than double upward durational departure from the presumptive sentencing range. The court of appeals affirmed, concluding that the rules of evidence do not apply during a Blakely court trial. The Supreme Court affirmed as modified, holding that the rules of evidence apply in a Blakely court trial, but there was no objection and the error was not plain. View "State v. Sanchez-Sanchez" on Justia Law

Respondent was pulled over by a police office on suspicion of driving while impaired for taking a wide right turn and weaving once within his lane around 2 a.m. Respondent was arrested and subsequently charged with second degree driving while impaired. Respondent moved to dismiss the charges, arguing that the arresting officer lacked a valid basis for the traffic stop. The trial court denied the motion to dismiss. Respondent was subsequently found guilty of one count of second-degree driving while impaired-alcohol concentration of 0.08 or more within two hours. The court of appeals reversed, concluding that the stop was improper. The Supreme Court reversed, holding that, under the totality of the circumstances, the arresting officer had a reasonable, articulable suspicion to justify the vehicle stop. View "State v. Morse" on Justia Law