Justia Minnesota Supreme Court Opinion Summaries

Defendant was convicted of three counts of murder in connection with the death of his two-year-old niece. While Defendant’s appeal was pending, new evidence was identified. The State then sought, and a grand jury returned, an amended indictment for five counts of murder. After a new trial, Defendant was convicted of five counts of murder. The Supreme Court reversed, holding that the district court (1) did not err when it seated jurors who knew about Defendant’s first conviction; but (2) abused its discretion when it allowed a juror who exhibited actual bias against Defendant and was not adequately rehabilitated to sit in judgment of Defendant. Remanded for a new trial. View "State v. Fraga" on Justia Law

After a jury trial, Appellant was found guilty of first-degree premeditated murder and first-degree felony murder. The district court sentenced Appellant to life imprisonment without the possibility of release on the first-degree premeditated murder conviction. The Supreme Court affirmed, holding (1) the district court did not err in denying Appellant’s motion to suppress statements he made to police; (2) the district court did not abuse its discretion when it declined to give Appellant’s requested jury instruction on circumstantial evidence; and (3) the evidence was sufficient to support Appellant’s murder convictions. View "State v. Fox" on Justia Law

After a jury trial, Appellant was found guilty of failing to register as a predatory offender. The district court imposed a presumptive sentence of sixteen months imprisonment and a ten-year conditional-release term under Minn. Stat. 422.052(3). The court imposed the conditional-release term based on a previous finding by an administrative committee of the Department of Corrections that had assessed Appellant as a high-risk, level-III offender. Several years later, Appellant moved to correct his sentence, arguing that a jury, not the judge, was constitutionally required to make the finding regarding his risk-level status. The district court denied Appellant’s motion. The court of appeals affirmed. The Supreme Court reversed and vacated Appellant’s ten-year conditional-release term, holding that Appellant had the right to have a jury determine whether he was a risk-level-III offender at the time of his offense. View "State v. Her" on Justia Law

Appellant pleaded guilty to one count of third-degree sale of a narcotic drug and was sentenced to fifteen months’ imprisonment. Appellant later sought postconviction relief seeking to withdraw his guilty plea for lack of an adequate factual basis. Specifically, Appellant argued that because the factual basis for his plea was his admission that he gave cocaine to his wife to hide when police officers pulled over the car in which he was a passenger, his testimony at the plea hearing did not support his conviction for a “sale” because he did not admit that he relinquished possession of the controlled substance. The postconviction court denied Appellant’s petition, concluding that the statutory definition of “sell” requires only a physical transfer of the possession of the contraband. The court of appeals affirmed. The Supreme Court reversed, holding (1) the facts to which Defendant admitted during his guilty plea colloquy did not show that his conduct fell within the definition of “sell” in Minn. Stat. 152.01(15a)(1); and (2) because there was not a sufficient factual basis for Appellant’s plea, his motion to withdraw his guilty plea should be granted. View "Barrow v. State" on Justia Law

Pursuant to a plea agreement, Defendant pleaded guilty to second-degree criminal sexual conduct and first-degree aggravated robbery in exchange for the State dismissing several charges. Defendant agreed to receive a sentence that was an upward durational departure. The district court sentenced Defendant according to the terms of the plea agreement. Defendant later filed a requested relief under Minn. R. Crim. P. 27.03(9), arguing that the court had impermissibly sentenced him. The district court denied relief. The court of appeals affirmed, concluding that Defendant could not challenge his sentence in a motion to correct his sentence. The Supreme Court affirmed, holding (1) because Defendant’s challenge to his sentence implicated more than simply his sentence, it is properly viewed as a petition for postconviction relief under Minn. Stat. 590.01, not as a motion to correct a sentence under Rule 27.03; and (2) Defendant’s request is time-barred by section 590.01(4)(a). View "State v. Coles" on Justia Law

A reporter from the Star Tribune submitted a request for data to the Minnesota Joint Underwriting Association (MJUA), an entity created by the Legislature to provide insurance for people or entitled who are required to have insurance and are unable to obtain insurance through ordinary methods. MJUA sought a written advisory opinion from the Commissioner of the Department of Administration as to whether MJUA was a state agency subject to the Minnesota Government Data Practices Act (MGDPA). The Commissioner declined to issue an advisory opinion. MJUA then commenced a lawsuit for declaratory relief seeking a declaration that it was not a governmental agency subject to the MGDPA. The district court granted the Star Tribune’s motion for partial judgment on the pleadings and ordered MJUA to comply with the MGDPA, concluding that MJUA is a state agency. The court of appeals reversed in part, holding that MJUA is not a governmental entity subject to the MGDPA. The Supreme Court affirmed, holding that MJUA is not a state agency subject to the MGDPA. View "Minn. Joint Underwriting Ass’n v. Star Tribune Media Co." 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 conviction arose from a homicide that occurred during an aggravated robbery. The Supreme Court affirmed, holding (1) the evidence was sufficient to uphold Defendant’s conviction, as the State introduced sufficient evidence to prove Defendant’s guilt as an accomplice to the murder; and (2) any error in the district court’s admission into evidence of recordings of portions of Defendant’s interrogation that occurred after Defendant told the officers, “ain’t no sense in talking no more man” was harmless beyond a reasonable doubt because the verdict was surely unattributable to the error. View "State v. McAllister" on Justia Law

Respondents brought an action against Appellant, their insurer, after Appellant denied their claim for property damage. The district court dismissed the action as untimely, concluding that although Respondents made service before the limitations period in the insurance policy expired, the action was untimely because they filed the affidavit of compliance after the policy’s limitations period had expired. The court of appeals reversed, concluding that that the affidavit of compliance may be filed after a limitations period has expired. The Supreme Court affirmed, holding that because Respondents filed the affidavit of compliance before the return day of the process, the service of process was effective, and Respondents’ suit was not barred by the limitations period in their insurance policy. View "Meeker v. IDS Prop. Cas. Ins. Co." on Justia Law

Appellant pleaded guilty to first-degree sexual conduct. Appellant was sentenced to a term of 144 months. Appellant later filed a petition for postconviction relief seeking to withdraw his guilty plea, alleging that his guilty plea was not knowingly, voluntarily, and intelligently made. The postconviction court denied the request for relief. The court of appeals affirmed, noting that the petition did not meet the basic requirements of the postconviction statute. The Supreme Court affirmed, holding that because Appellant did not provide a single factual allegation to support his claim that his guilty plea was not knowingly, voluntarily, or intelligently made, his petition did not meet the requirements of Minn. Stat. 590.02(1)(1). View "Matakis v. State" on Justia Law

After a jury trial, Appellant was convicted of first-degree premeditated murder and first-degree murder while committing burglary arising from the stabbing death of an eleven-year-old. The Supreme Court affirmed Appellant’s conviction for premeditated first-degree murder but vacated his conviction for first-degree murder while committing burglary. Appellant later filed a petition for postconviction relief arguing that he was entitled to a new trial to consider evidence that was purportedly new and exculpatory. The postconviction court denied the petition without holding an evidentiary hearing. Appellant subsequently brought the instant pro se petition for postconviction relief, alleging ineffective assistance of trial counsel and appellate counsel and loss of evidence claims. The postconviction court summarily denied the petition, concluding (1) appellate counsel’s representation did not fall below an objective standard of reasonableness, and (2) Appellant’s remaining claims were procedurally barred under State v. Knaffla. The Supreme Court affirmed, holding (1) Appellant’s ineffective assistance of appellate counsel claim failed as a matter of law; and (2) Appellant’s remaining claims were time barred. View "Fort v. State" on Justia Law