Justia Minnesota Supreme Court Opinion Summaries

After a jury trial in 2003, Appellant was found guilty of first degree murder and sentenced to life imprisonment without the possibility of release. In 2014, Appellant filed his sixth postconviction petition, alleging newly discovered evidence, juror misconduct, and that cumulative errors required a new trial in the interests of justice. The postconviction court denied Appellant’s petition without holding an evidentiary hearing. The Supreme Court affirmed, holding that the postconviction court did not abuse its discretion in denying the petition, as the record conclusively showed that Appellant’s claims were either harmless beyond a reasonable doubt, procedurally barred, or meritless. View "Colbert v. State" on Justia Law

In 1987, after a jury trial, Appellant was convicted of first-degree murder while committing criminal sexual conduct. Appellant was sentenced to life in prison. In 2014, Appellant brought a motion to correct his sentence. The postconviction court treated Appellant’s motion as a petition for postconviction relief and denied it because of Appellant’s failure to file it until after the two-year postconviction statute of limitations had expired. The Supreme Court affirmed, holding that the postconviction court did not abuse its discretion when it denied relief to Appellant on the grounds that the statute of limitations had expired. View "Wayne v. State" on Justia Law

The Minnesota Board on Judicial Standards brought a formal complaint against Hon. Alan F. Pendleton, Judge of the District Court of the Tenth Judicial District, alleging that Pendleton violated the Code of Judicial Conduct and the Minnesota Constitution. A panel appointed by the Supreme Court concluded that Judge Pendleton violated several sections of the Code of Judicial Conduct and Minn. Const. art. VI, 4 and recommended that the judge be censured and suspended from judicial office without pay for at least six months. Judge Pendleton appealed. The Supreme Court affirmed, holding (1) the Board proved by clear and convincing evidence that Judge Pendleton failed to reside within his judicial district during his continuation in office and that he made a knowingly false statement regarding his residency in his affidavit of candidacy; (2) Judge Pendleton was not denied due process of law by irregularities in the proceedings before the Board and the panel; and (3) the appropriate judicial discipline is removal from office. View "Inquiry into the Conduct of Hon. Alan F. Pendleton" on Justia Law

Appellant, a Delaware limited liability company, made short-term, high-interest payday loans to Minnesota residents over the Internet. Integrity conceded that its payday loans did not comply with several provisions of Minnesota’s payday-lending law. In 2011, the Minnesota Attorney General sued Integrity, alleging that it had violated Minnesota’s payday-lending law. Integrity counterclaimed by requesting a declaratory judgment that Minnesota’s payday-lending law was unconstitutional under the extraterritoriality principle of the Commerce Clause, which prohibits a state from regulating commerce that occurs wholly outside the state. The district court granted summary judgment to the State. The court of appeals affirmed. The Supreme Court affirmed, holding that Minnesota’s payday-lending law does not violate the Commerce Clause. View "State v. Integrity Advance, LLC" on Justia Law

After a jury trial, Defendant was found guilty of first-degree assault. The jury found that certain facts existed to support a sentencing departure under the repeat offender aggravating factor. After a sentencing hearing, the district court departed upward from the presumptive sentence range of 135-189 months and sentenced Defendant to the statutory maximum sentence of 240 months. The court of appeals affirmed the sentence, concluding that the repeat offender aggravating factor provided a valid ground for departure and that the district court did not abuse its discretion by imposing a 240-month sentence. The Supreme Court affirmed, holding (1) the district court properly applied the repeat offender aggravating factor to Defendant’s first-degree assault conviction; and (2) the district court did not abuse its discretion in imposing a 240-month sentence. View "State v. Meyers" on Justia Law

In 1997, Appellant was convicted of first-degree premeditated murder and attempted first-degree murder. In 2003, Appellant filed his first postconviction petition. The postconviction court denied the petition after holding an evidentiary hearing. In 2013, Appellant filed his second postconviction petition, claiming that he received ineffective assistance of trial and appellate counsel. The postconviction court denied the petition without holding an evidentiary hearing, concluding that the petition was both untimely under the two-year statute of limitations for filing a postconviction petition and procedurally barred under State v. Knaffla. The Supreme Court affirmed, holding that Appellant’s claims were procedurally barred. View "Williams v. State" on Justia Law

After Employee ended his employment with Employer he applied for and received state unemployment benefits from the Department of Employment and Economic Development (DEED) and supplemental unemployment benefits (SUB) through a plan offered by Employer. DEED determined that the SUB plan payments counted as “wages” under Minn. Stat. 268.035(29)(A) and determined that Employee had been overpaid state unemployment benefits. An unemployment law judge affirmed. The court of appeals reversed, concluding that Employee was entitled to keep the state unemployment benefits. The Supreme Court affirmed, holding the SUB plan payments Employee received were not “wages” for purposes of his eligibility for state unemployment benefits, and therefore, Employee was not overpaid state unemployment benefits. View "Engfer v. Gen. Dynamics Advanced Info. Sys., Inc." on Justia Law

After being placed on probation, Appellant was cited for consumption of alcohol by a minor and disorderly conduct. The State subsequently moved to have Appellant’s probation revoked, and the State cited Appellant for misdemeanor contempt of court. Appellant moved to dismiss the criminal contempt charge. The district court granted the motion, concluding that the statute charged does not cover violations of probationary terms. Meanwhile, Appellant’s probation was revoked, and the sentence was executed. The Supreme Court affirmed the dismissal of the contempt charge after determining and clarifying the relationship between both the contempt and probation statutes, holding that a willful violation of of a “term” of probation prescribed at sentencing does not itself constitute the crime of violation of a “mandate of a court” under the criminal contempt statute. View "State v. Jones" on Justia Law

After a jury trial, Defendant was convicted of one count of first-degree murder and two counts of attempted first-degree murder. The Supreme Court affirmed the convictions, holding (1) the district court’s exclusion from the courtroom members of the public that did not have photographic identification did not constitute a partial courtroom closure; (2) even if the district court’s exclusion of certain evidence supporting an alternative motive of accomplice witnesses was erroneous, the error was harmless; (3) even if the district court erred in admitting testimony from a gang expert identifying Defendant as a gang member, the error was harmless; (4) the district court did not plainly err in instructing the jury on aiding and abetting liability; (5) the district court did not plainly err by not giving a limiting instruction sua sponte regarding Appellant’s prior convictions; (6) the district court did not violate Defendant’s right to a speedy trial; (7) the district court did not err in admitting into evidence a handwritten note seized from Defendant’s jail cell; (8) Defendant waived review of whether the admission into evidence of prison phone call recordings was erroneous; and (9) the cumulative effect of the two assumed errors did not deprive Defendant of a fair trial. View "State v. Taylor" on Justia Law

After a jury trial, Appellant was convicted of felony fourth-degree assault of a peace officer in violation of Minn. Stat. 609.2231(1). Appellant appealed, arguing that the district court abused its discretion by declining to instruct the jury that the act of intentionally throwing or otherwise transferring bodily fluids at or onto an officer, in itself, is a physical assault only when the defendant inflicted or attempted to inflict bodily harm on the officer. The court of appeals affirmed, concluding that the transfer of bodily fluids onto an officer in itself constitutes fourth-degree felony assault. The Supreme Court reversed, holding (1) the unambiguous language of section 609.2231(1) requires that the State prove the elements of a physical assault in addition to proving that a defendant intentionally threw or transferred bodily fluids at or onto the officer; and (2) the district court in this case erred by omitting the element of “physical assault” in its instructions to the jury. View "State v. Struzyk" on Justia Law