Justia Civil Rights Opinion Summaries

The warrantless search of Defendant’s property violated Defendant’s Fourth Amendment rights in this case.Here, an officer entered Defendant’s property, examined a stolen camper trailer and then, after obtaining Defendant’s consent, searched Defendant’s home. Defendant filed a motion to suppress, arguing that the officer’s examination of the camper was unconstitutional and tainted his subsequent consent to the search of his home. The district court denied the motion to suppress, concluding that because the camper was on a driveway that was impliedly open to the public, the officer’s entry onto Defendant’s property was lawful and that the officer had authority to seize the camper under the plain-view doctrine. The court of appeals reversed. The Supreme Court affirmed, holding (1) the camper was located on property that was afforded the constitutional protections of the home; and (2) the officer’s conduct was beyond the objectively reasonable scope of any implied license to enter Defendant’s property, and therefore, the warrantless search violated Defendant’s Fourth Amendment rights. View "State v. Chute" on Justia Law

The Fifth Amendment privilege against self-incrimination does not protect a person from being ordered to prove a fingerprint to unlock a seized cellphone.The police lawfully seized a cellphone from Defendant and attempted to execute a valid warrant to search the cellphone, which had a fingerprint-scanner security lock that prevented the search. When Defendant refused to block the cellphone with his fingerprint the district court ordered Defendant to provide his fingerprint so the police could search the cellphone’s contents. The court of appeals affirmed, concluding that providing a fingerprint was not privileged under the Fifth Amendment. The Supreme Court affirmed, holding that because providing the fingerprint elicited only physical evidence from Defendant and did not reveal the contents of his mind, no violation of the Fifth Amendment privilege against self-incrimination occurred. View "State v. Diamond" on Justia Law

Under the totality of the circumstances of this case, the police did not violate the Fourth Amendment when, during their execution of a warrant to search a home, they searched a purse that belonged to a guest at the home.Defendant was charged with third-degree controlled-substance crime for possessing methamphetamine. Defendant moved to suppress the methamphetamine found in her pursue, arguing that the search violated the Fourth Amendment because the search of her purse was beyond the scope of the search warrant. The district court denied the motion. The court of appeals affirmed. The Supreme Court affirmed, holding that, taken together, the facts showed that the search of Defendant’s purse was reasonable, and therefore, the search did not violate her Fourth Amendment rights. View "State v. Molnaux" on Justia Law

The postconviction court did not abuse its discretion in when it denied Appellant’s second petition for postconviction relief without holding an evidentiary hearing.Appellant was found guilty of two counts of first-degree murder and sentenced to consecutive terms of life imprisonment without the possibility of release. The Supreme Court affirmed the convictions on direct appeal. In his first petition for postconviction relief, Appellant raised claims of ineffective assistance of trial and appellate counsel. The Supreme Court affirmed the postconviction court’s summary denial of the first petition. After hiring a private investigator to look into his case, Appellant filed a second postconviction petition. The Supreme Court affirmed the postconviction court’s summary denial of the petition, holding that even if Appellant proved the facts alleged in the petition at an evidentiary hearing, the petition, files, and records of the proceedings conclusively showed that Appellant was not entitled to relief. View "Zornes v. State" on Justia Law

Plaintiff may file a petition for an order declaring her eligible for compensation under Minnesota’s Imprisonment and Exoneration Remedies Act, Minn. Stat. 590.11, 611.362-.368.Several years after the Supreme Court reversed Plaintiff’s conviction for second-degree manslaughter Plaintiff filed a petition seeking remuneration as an “exonerated” individual under section 590.11. The district court denied the petition, concluding (1) Petitioner was not “exonerated” under the statute because the prosecutor never dismissed the second-degree-manslaughter charge, and (2) the prosecutorial-dismissal requirement does not violate equal protection. The court of appeals, however, ruled that the prosecutorial-dismissal requirement violates equal protection and severed the requirement from the remainder of the provision rather than invalidating the entirety of section 590.11(1)(1)(i). The Supreme Court reversed, holding (1) Plaintiff was not “exonerated” under the statute when the Supreme Court reversed her conviction; (2) a statute cannot constitutionally require a prosecutor to dismiss charges that have already been reversed by an appellate court; and (3) the remedy for the as-applied equal-protection violation is to sever section 590.11(1)(1)(i) from the remainder of the statute. View "Back v. State" on Justia Law

The part of Minnesota’s disorderly-conduct statute that prohibits “disturb[ing]” assemblies or meetings, Minn. Stat. 609.72(1)(2), violates the First Amendment.Defendant was convicted of disorderly conduct under section 609.72(1)(2) after a jury trial. On appeal, Defendant argued that the statute violates the First Amendment because it is unconstitutionally overbroad, unconstitutionally vague, and unconstitutional as applied. The court of appeals affirmed, concluding that the constitute was constitutional and was not subject to standard overbreadth analysis. The Supreme Court reversed, holding that the statute suffers from substantial overbreadth and that there is no reasonable narrowing construction of the statute. View "State v. Hensel" on Justia Law

The Supreme Court declined Appellants’ invitation to depart from the United States Supreme Court’s decision in Camara v. Municipal Court, 387 U.S. 523 (1967) and hold that Minnesota’s constitution requires that an administrative search warrant be supported by probable cause of the sort required in a criminal investigation. Camara held that an administrative warrant satisfies the probable cause requirement if reasonable legislative or administrative standards for conducting an unconsented-to rental housing inspection are satisfied with respect to a particular dwelling. In this case, the City of Golden Valley petitioned the district court for an administrative search warrant to search rental property for compliance with the city code. The district court denied the petition for the administrative search warrant, concluding that the issuance of such a search warrant was foreclosed without suspicion of a code violation. The court of appeals reversed. The Supreme Court affirmed, holding that the Minnesota Constitution does not require individualized suspicion of a code violation to support an administrative search warrant for a rental housing inspection. View "City of Golden Valley v. Wiebesick" on Justia Law

Appellant, a juvenile offender, challenged the district court’s imposition of three consecutive sentences of life imprisonment with the possibility of release after thirty years on each sentence for his three murder convictions. Appellant argued, among other things, that the rule announced in Miller v. Alabama and clarified in Montgomery v. Louisiana should apply to his case because his consecutive sentences were, in the aggregate, the functional equivalent of life imprisonment without the possibility of release. The Supreme Court affirmed, holding (1) this court declines to extend the Miller/Montgomery to include Appellant or other similarly situated offenders because the United States Supreme Court has not squarely addressed the issue of whether consecutive sentences should be viewed separately when conducting a proportionality analysis; and (2) Appellant’s three consecutive sentences do no unfairly exaggerate the criminality of his conduct. View "State v. Ali" on Justia Law

Respondent worked as a police officer for Appellant City of Minneapolis. When the City transferred Respondent from his position with the Violent Offender Task Force to another police unit Respondent was fifty-four years old. In November 2011, Respondent filed a complaint with Appellant’s human resources department, claiming that the transfer was due to age discrimination. More than one year after Peterson filed his complaint, Appellant concluded that the transfer was not because of age discrimination. In March 2014, Respondent commenced this action against Appellant, claiming that the City discriminated against him based on his age in violation of the Minnesota Human Rights Act (MHRA). The district court granted partial summary judgment for the City, concluding that Respondent’s claim was not filed within the relevant one-year limitations period. The court of appeals reversed, concluding that the statute of limitations was suspended during the period of time in which Appellant’s human resources department was investigating Respondent’s claim. The Supreme Court affirmed, holding that Respondent and Appellant were voluntarily engaged in a dispute resolution process involving a claim of unlawful discrimination during Appellant’s investigation of Respondent’s claim, which triggered Minn. Stat. 363A.28(3)(b) and suspended the one-year limitations period. View "Peterson v. City of Minneapolis" on Justia Law

After Nicole LaPoint applied for a job with Family Orthodontics, the company’s owner, Dr. Angela Ross, offered LaPoint a job as an orthodontic assistant. When LaPoint told Dr. Ross that she was pregnant, Family Orthodontics rescinded its job offer. LaPoint sued the company for sex discrimination under the Minnesota Human Rights Act. The district court entered judgment in favor of Family Orthodontics. The court of appeals reversed, ruling, as a matter of law, that Family Orthodontics had discriminated against LaPoint because of her pregnancy. The Supreme Court reversed, holding (1) to the extent the court of appeals applied an incorrect legal standard to evaluate LaPoint’s claim, it erred; and (2) the district court’s findings were reasonably supported by the evidence, but it was unclear whether the district court would have made the same findings had it applied the correct law regarding animus. Remanded. View "LaPoint v. Family Orthodontics, P.A." on Justia Law