Justia Civil Rights Opinion Summaries

Articles Posted in Minnesota Supreme Court

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The Supreme Court affirmed Defendant's convictions for first-degree murder and attempted first-degree murder, holding that Defendant's allegations of error did not warrant reversal of his convictions. Specifically, the Court held (1) the admission of certain evidence did not violate the Fourth Amendment to the United States Constitution or the substantive requirements of Minn. Stat. 626A.42; (2) to the extent the challenged evidence violated Minn. R. Evid. 702 the error was harmless; (3) the district court did not clearly err when it determined that Defendant failed to make a prima facie showing of discrimination under step one of the Batson v. Kentucky, 476 U.S. 79 (1986), inquiry; and (4) Defendant's claims of ineffective assistance of counsel and prosecutorial misconduct were without merit. View "State v. Harvey" on Justia Law

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The Supreme Court reversed the decision of the court of appeals affirming Defendant's conviction, holding that a body cavity search performed by forcing Defendant to be strapped down and sedated in order to undergo an invasive anoscopy against his will in the presence of nonmedical personnel was unreasonable under the Fourth Amendment. After Defendant was strapped down and sedated he was forced against his will to undergo an anoscopy. During the procedure, the doctor located a plastic baggie containing cocaine in Defendant's body cavity. The State charged Defendant with one count of fifth-degree possession of a controlled substance. Defendant moved to suppress evidence of the drugs, arguing that the search, even though conducted pursuant to a valid search warrant, was unreasonable. The district court denied the motion, and Defendant was convicted. The court of appeals affirmed, concluding that the anoscopy was a reasonable search. The Supreme Court reversed, holding that the extreme intrusion of Defendant's dignitary rights by the coerced anoscopy outweighed the State's need to retrieve relevant evidence of drug possession, and therefore, the evidence retrieved from the search must be suppressed. View "State v. Brown" on Justia Law

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The Supreme Court affirmed the judgment of the district court denying Defendant's petition for postconviction relief, holding that the district court did not err in denying the petition without holding an evidentiary hearing. Defendant was convicted of first-degree murder as an accomplice. The Supreme Court affirmed on direct appeal. Thereafter, Defendant filed the present petition for postconviction relief, alleging several claims of error. The district court denied the petition without a hearing, reasoning that Defendant's arguments were either procedurally barred or lacked merit. The Supreme Court affirmed, holding that Defendant's claims were either procedurally barred or failed on the merits. View "Onyelobi v. State" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the district court suppressing the results of Defendant's blood test, holding that the limited right to counsel established in Friedman v. Commissioner of Public Safety, 473 N.W.2d 828 (Minn. 1991), does not apply when an individual is asked to submit to a blood test pursuant to a warrant. After Defendant was arrested for driving while impaired, the police officer obtained a search warrant to take a sample of her blood for alcohol concentration testing. The officer read Defendant the implied-consent advisory for blood and urine tests, and Defendant allowed her blood to be drawn. Defendant moved to have the results of her blood test suppressed, arguing that, under Friedman, she had a limited constitutional right to consult with counsel before deciding whether to submit to a blood test. The district court agreed. The Supreme Court disagreed, holding that the limited right to counsel under the Minnesota Constitution recognized in Friedman does not apply when a driver is presented with the choice to submit to a blood test pursuant to a search warrant. View "State v. Rosenbush" on Justia Law

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The Supreme Court affirmed the judgment of the postconviction court summarily denying Defendant's petition for postconviction relief arguing that counsel provided ineffective assistance and that an expert witness for the State provided unreliable testimony at trial, holding that the postconviction court did not err. Defendant was convicted of first-degree murder and sentenced to life imprisonment. The Supreme Court affirmed Defendant's conviction on direct appeal. Defendant later filed a petition for postconviction relief, which the postconviction court summarily denied. The Supreme Court affirmed, holding that Defendant's claims were either meritless or time-barred. View "Odell v. State" on Justia Law

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The Supreme Court affirmed Defendant's convictions of first-degree felony murder, attempted first-degree felony murder, drive-by shooting (the underlying felony), and other offenses, holding that the evidence was sufficient to support the drive-by shooting conviction and that the prosecutor did not engage in prosecutorial misconduct. On appeal, Defendant argued, among other things, that the evidence was insufficient to prove that he discharged a firearm "at or toward" a building or vehicle and that the prosecutor committed prosecutorial misconduct when she argued in rebuttal that Defendant's closing argument was trying to play on the jury's emotions. The Supreme Court affirmed, holding (1) there was sufficient evidence for a reasonable jury to find that Defendant discharged a firearm "toward" a building; (2) the prosecutor did not commit misconduct; and (3) Defendant's remaining pro se arguments were without merit. View "State v. Waiters" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals affirming Defendant's convictions for first-degree sexual conduct and domestic assault by strangulation, holding that Minn. R. Crim. P. 9.01 subs. 1-1a does not authorize an inspection of a crime scene in the control of a third party and that, even if Defendant had a constitutional right to inspect the crime scene, any error in denying that right was harmless. Before trial, Defendant filed a motion to allow his counsel and investigator to enter his former residence to inspect and photograph the crime scene. The district court denied the motion. The court of appeals held that Defendant had a right under Rule 9.01, subs. 1-1a, to inspect the crime scene but was not entitled to a new trial because the denial of his motion to inspect was harmless. The Supreme Court affirmed, holding (1) Rule 9.01, subs. 1-1a, does not allow the State to allow a defendant to inspect a crime scene that is the control of a third party; and (2) even if assuming Defendant had the constitutional inspection rights he asserted here, any error in denying his motions to inspect the property was harmless beyond a reasonable doubt. View "State v. Lee" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals upholding the district court's ruling that the admission of statements made by Defendant using a foreign language interpreter did not violate the Confrontation Clause of the Sixth Amendment to the United States Constitution or hearsay rules, holding that the Confrontation Clause was not violated in this case and that the statements were not subject to the hearsay rules. The district court convicted Defendant of first-degree criminal sexual conduct and sentenced him to 144 months in prison. Defendant appealed, arguing that the admission of his translated statements violated the Confrontation Clause and hearsay rules. The court of appeals upheld the district court's ruling that the court's admission of the interpreter's translated statements were proper. The Supreme Court affirmed, holding that the translated statements did not violate the Confrontation Clause and that the district court did not abuse its discretion in admitting the translated statements into evidence over the hearsay objection by Defendant. View "State v. Lopez-Ramos" on Justia Law

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The Supreme Court affirmed the judgment of the postconviction court summarily denying Appellant's claims for ineffective assistance of trial and appellate counsel without holding an evidentiary hearing, holding that Appellant's claims were barred by the relevant statute of limitations. Appellant was convicted of first-degree premeditated murder under an aiding-and-abetting theory of liability. The district court imposed a sentence of life without the possibility of release. Appellant later filed his postconviction petition requesting an evidentiary hearing on his claims for ineffective assistance of trial and appellate counsel and mentioning a motion for testing conducted under Minn. Stat. 590.01, subd. 1a. The postconviction court concluded that Appellant's claims were barred by the two-year statute of limitations, Minn. Stat. 590.01, subd. 4. The Supreme Court affirmed, holding (1) Appellant's claims were barred by the two-year statute of limitations; and (2) Appellant's reference to testing did not satisfy the requirements of subdivision 1a. View "Jackson v. State" on Justia Law

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The Supreme Court reversed the decision of the court of appeals dismissing the Minnesota Department of Natural Resource's (DNR) appeal of an order of the Chippewa/Swift Joint Board of Commissioners (Board) reestablishing the records for a public drainage system pursuant to Minn. Stat. 103E.101(4)(a), holding that the Board's order was a quasi-judicial decision subject to certiorari review. In dismissing the appeal, the court of appeals held that the order reestablishing records was not a quasi-judicial decision subject to certiorari review because the order was not a binding decision regarding the disputed claim but, rather, a preliminary step in a repair process. The Supreme Court disagreed, holding that record-reestablishment orders are final and binding and are therefore quasi-judicial decisions subject to quasi-judicial review. View "Minnesota Department of Natural Resources v. Chippewa/Swift Joint Board of Commissioners" on Justia Law