Justia Civil Rights Opinion Summaries

The Supreme Court held that Minn. Stat. 609.344(1)(b) and 609.345(1)(b), which prohibit sexual penetration and sexual conduct where the complainant is between thirteen and sixteen years of age and the actor is more than two years older than the complainant, are constitutional even though they prevented Defendant from asserting a mistake-of-age defense.The statutes at issue provide a mistake-of-age defense but only to actors who are no more than 120 months older than the complainant. On appeal, the court of appeals held that the statutes did not violate the guarantees of substantive due process and equal protection under the federal and state constitutions and did not unconstitutionally impose strict liability. The Supreme Court affirmed, holding (1) sections 2609.344(1)(b) and 609.345(1)(b) do not violate substantive due process or equal protection by limiting a mistake-of-age defense to defendants who are no more than 120 months older than the complainant; and (2) the statutes do not impose strict liability but, instead, require proof beyond a reasonable doubt that the actor had a general intent to engage in sexual penetration or sexual contact with the complainant. View "State v. Holloway" on Justia Law

The Supreme Court affirmed Appellant’s conviction for first- and second-degree murder on an aiding-and-abetting theory. The Court held (1) even if it was error for the district court to admit into evidence Appellant’s statement to police, the error was harmless beyond a reasonable doubt; (2) the district court plainly erred by giving a no-adverse-inference instruction to the jury without Appellant’s consent, but the error was not prejudicial; and (3) assuming, without deciding, that the prosecutor committed misconduct during closing argument by “indirectly alluding” to Appellant’s failure to testify, the prosecutor’s argument was not prejudicial. View "State v. Johnson" on Justia Law

The Supreme Court held that four irrevocable inter vivos trusts (the Trusts) lacked sufficient relevant contacts with Minnesota during the relevant tax year to be permissibly taxed, consistent with due process, on all sources of income as “resident trusts.”The Trusts filed their 2014 Minnesota income tax returns under protest, asserting that Minn. Stat. 290.01(7b)(a)(2), the statute classifying them as resident trusts, was unconstitutional as applied to them. The Trusts sought refunds for the difference between taxation as resident trusts and taxation as non-resident trusts. The Commissioner of Revenue denied the refund claims. The Minnesota Tax Court granted summary judgment for the Trusts, holding that the statutory definition of “resident trust” violates the Due Process Clauses of the Minnesota and United States Constitutions as applied to the Trusts. The Supreme Court affirmed, holding that, for due process purposes, the State lacked sufficient contacts with the Trusts to support taxation of the Trusts’ entire income as residents. View "Fielding v. Commissioner of Revenue" on Justia Law

The Supreme Court affirmed in part and reversed and remanded in part the postconviction court’s denial of Petitioner’s second petition for postconviction relief without holding an evidentiary hearing.Petitioner was found guilty of first-degree premeditated murder and sentenced to life in prison without the possibility of release. After his first postconviction petition was summarily denied, Petitioner filed his second postconviction petition, alleging the existence of sixteen pieces of newly discovered evidence. The postconviction court denied the second petition without holding an evidentiary hearing, concluding that the petition was untimely because the facts alleged in the petition did not satisfy the statutory newly-discovered-evidence exception. The Supreme Court reversed in part, holding (1) the postconviction court abused its discretion by making improper credibility determinations without holding an evidentiary hearing; and (2) the facts alleged in support of Petitioner’s remaining claims did not satisfy the newly-discovered-evidence or interests-of-justice exceptions to the two-year statute of limitations. View "Anderson v. State" on Justia Law

The Supreme Court affirmed the postconviction court’s denial of Petitioner’s petition for postconviction relief, holding that the postconviction court did not abuse its discretion.Petitioner was found guilty of first-degree premeditated murder and first-degree felony murder. Petitioner was sentenced to life imprisonment without the possibility of release for the murder conviction. The Supreme Court affirmed. Petitioner later filed a petition for postconviction relief, alleging six grounds for postconviction relief. The postconviction court rejected the petition without holding an evidentiary hearing. The Supreme Court affirmed, holding that Petitioner’s claims were either procedurally barred or failed as a matter of law. View "Fox v. State" on Justia Law

The limited right to counsel recognized in Friedman v. Commissioner of Public Safety, 473 N.W. 2d 828 (Minn. 1991), applies only to implied-consent cases.The district court in this case suppressed the results of a urine sample provided by Defendant at a jail after his arrest for driving while impaired (DWI) because the sheriff’s deputy, when asking Defendant if he would consent to urine testing, failed to read the implied-consent advisory that would have advised Defendant of his right to counsel. The court concluded that, by failing to read the advisory, the deputy failed to allow Defendant to vindicate his right to counsel prior to testing. The court of appeals reversed. The Supreme Court affirmed, holding (1) because the officer did not read the implied-consent advisory in this case, under Friedman, the limited right to counsel was not triggered; and (2) therefore, the district court erred in suppressing the urine test results on that ground. View "State v. Hunn" on Justia Law

The Supreme Court reversed the decisions of the court of appeals and district court that Respondent’s due process rights were violated when he was read an inaccurate implied consent advisory after his arrest on suspicion of driving while impaired.Respondent refused to submit to either a urine or a blood test. Thereafter, the Commissioner of Public Safety revoked Respondent’s driver’s license for refusing to submit to a test. Relying on McDonnell v. Commissioner of Public Safety, 473 N.W.2d 848 (Minn. 1991), the district court rescinded the revocation after finding that the implied consent advisory violated Respondent’s due process rights because it incorrectly stated that refusal to submit to a urine test was a crime. The court of appeals affirmed on the basis that the threat of legally impossible criminal charges for refusal to submit to a urine test violated due process. The Supreme Court reversed, holding that because Respondent did not rely on the implied consent advisory to his detriment, and instead refused to submit to testing, no due process violation occurred under McDonnell. View "Johnson v. Commissioner of Public Safety" on Justia Law

Appellant failed to establish that he was prejudiced by the implied consent advisory read to him after he was arrested on suspicion of driving while impaired, and therefore, Appellant was not entitled to a rescission of his license revocation under McDonnell v. Commissioner of Public Safety, 473 N.W.2d 848 (Minn. 1991).Appellant submitted to a blood test, and the test results showed an alcohol concentration above the legal limit. Appellant’s driver’s license was subsequently revoked. The district court sustained the revocation on the basis that Appellant voluntarily consented to the blood test. The Supreme Court affirmed, holding that Appellant was not entitled to a rescission of his license revocation under McDonnell because he did not even claim, much less establish, that he prejudicially relied on the implied consent advisory. View "Morehouse v. Commissioner of Public Safety" on Justia Law

Law enforcement officers did not violate Defendant’s Fifth Amendment privilege against self-incrimination when, after Defendant invoked his privilege against self-incrimination, they later asked him if he was willing to sign a written consent to the taking of a DNA sample and explained to him why they sought the sample.Defendant was charged with possession of a firearm by an ineligible person and possession of a short-barreled shotgun. Defendant filed a motion to suppress DNA evidence and his admission that he had handled the shotgun, claiming that the officers conducted a second custodial interrogation after he had invoked his privilege against self-incrimination. The district court denied the motion. The Supreme Court affirmed, holding that the officers did not violate Defendant’s constitutional privilege against self-incrimination because, although Defendant’s statements that he had already handled the shotgun were incriminating testimonial communications, none of the officers’ actions were reasonably likely to elicit an incriminating testimonial communication. Therefore, a Miranda warning was not required. View "State v. Heinonen" on Justia Law

Failing to register is a continuing crime that includes the entire range of dates on which Defendant failed to register in this case, and a jury was not required to find the date of Defendant’s current offense.Defendant was convicted of knowingly failing to register as a predatory offender. Under the Minnesota Sentencing Guidelines, prior felony sentences are used to calculate criminal history scores unless a period of fifteen years has elapsed between “the date of the current offense” and the expiration of the prior felony sentence (see Minn. Stat. 243.166). Defendant argued that “the date of the current offense” for his crime was the last day the offense occurred and that a jury must decide that date. The court of appeals concluded that “the date of the current offense,” which is a continuing offense, is the first day the offense occurs. The Supreme Court affirmed, holding (1) the district court did not err in including Defendant’s 1996 felony conviction in his criminal history score because fifteen years had not elapsed between the expiration of Defendant’s sentence for his 1996 conviction and the start of his current offense; and (2) Defendant’s sentence did not violate his Sixth Amendment right to a jury trial under Blakely v. Washington, 542 U.S. 296 (2004). View "State v. Washington" on Justia Law