Justia Civil Rights Opinion Summaries

Defendant was charged in May 2013 with two counts of first-degree criminal sexual conduct. When Defendant failed to appear for his first appearance, the district court issued a warrant for his arrest. In February 2015, Defendant was arrested for unrelated reasons. Before his omnibus hearing, Defendant moved to dismiss the charges, claiming that the twenty-one-month delay between the date he was charged and his eventual arrest violated his right to a speedy trial under the United States and Minnesota Constitutions. The district court granted Defendant’s motion and dismissed the charges after applying the four-factor balancing test from Barker v. Wingo. The court of appeals reversed, concluding that the third and fourth Barker factors did not weigh in Defendant’s favor, and therefore, on balance, the State had not violated Defendant’s constitutional right to a speedy trial. The Supreme Court affirmed as modified, holding that although the delay may have been attributable to the State’s negligence, Defendant’s failure to assert his speedy trial right weighed heavily against him and ultimately led to the conclusion that the State did not violate Defendant’s right to a speedy trial. View "State v. Osorio" on Justia Law

The State charged Defendant under Minn. Stat. 609.352, subd. 2a(2) with felony communication with a child describing sexual conduct after she sent sexually explicit images and messages to a fifteen-year-old boy. Defendant filed a motion to dismiss, arguing that section 609.352, subd. 2a(2) proscribes a substantial amount of speech that the First Amendment protects and thus facially violates the First Amendment. The district court concluded that the statute violates the First Amendment, and the court of appeals affirmed. The Supreme Court reversed, holding that 609.352, subd. 2a(2) is not substantially overbroad in relation to its plainly legitimate sweep. View "State v. Muccio" on Justia Law

After Appellant pleaded guilty to third-degree criminal sexual conduct, removal proceedings were initiated against him. In an attempt to avoid deportation, Appellant filed an emergency motion to withdraw his guilty plea, arguing, inter alia, that he received ineffective assistance of counsel because counsel failed accurately to inform him that his plea would lead to his removal from the United States. Specifically, Appellant argued that Padilla v. Kentucky required his attorney to advise him that the plea would result in his deportation, rather than just the deportation was a possibility. The postconviction court denied Appellant’s motion. The court of appeals affirmed. The Supreme Court affirmed, holding that Padilla did not require Appellant’s counsel to do anything more than provide a general warning about the immigration consequences of entering the plea, and therefore, Appellant’s counsel satisfied his obligation under the Sixth Amendment. View "Sanchez v. State" on Justia Law

Defendant was arrested and charged with drug-related crimes. The district court ordered Defendant’s pretrial release. The district court later found probable cause that Defendant had violated the conditions of her release and issued a warrant for her arrest. Officers then went to the residence of Defendant’s boyfriend. One officer opened an unlocked door, went inside, and arrested Defendant. While arresting her, the officer saw marijuana and a bong in plain view. Law enforcement then obtained a search warrant for the apartment of Defendant’s boyfriend. The state subsequently charged Defendant with two counts of fifth-degree possession of a controlled substance and possession of drug paraphernalia. The district court suppressed all fruits of Defendant’s arrest and dismissed the charges, concluding that the arrest was illegal because the warrant for Defendant's arrest did not authorize police to enter her boyfriend’s apartment. The court of appeals reversed. The Supreme Court affirmed, holding that neither the Fourth Amendment of the U.S. Constitution nor Article I, Section 10 of the Minnesota Constitution requires police to obtain a search warrant before entering a home to arrest a guest who is the subject of a lawfully issued arrest warrant. View "State v. deLottinville" on Justia Law

Defendant pled guilty to felony domestic assault in district court. Following sentencing, Ramsey County Community Corrections notified the district court that Defendant was required to register as a predatory offender due to his conviction. Defendant filed a motion to withdraw his guilty plea on the ground that he had not been aware that his conviction would trigger the requirement to register as a predatory offender. The district court denied the request. The court of appeals affirmed. The Supreme Court affirmed, holding that a defense attorney’s failure to advise a defendant about predatory offender registration requirements before the defendant enters a plea of guilty does not violate a defendant’s right to effective assistance of counsel, and therefore, Defendant was not entitled to withdraw his guilty plea. View "Taylor v. State" on Justia Law

Appellant was convicted of first-degree murder for the benefit of a gang on an accomplice-liability theory. The Supreme Court affirmed. After unsuccessfully filing two postconviction petitions, Appellant filed a third postconviction petition in which he alleged that three witnesses presented false testimony at his trial. Following an evidentiary hearing, the postconviction court denied Appellant’s third postconviction petition. The Supreme Court affirmed, holding (1) the postconviction court did not err when it rejected Appellant’s claim that the prosecutor intimidated a recanting witness when it apprised the witness of his Fifth Amendment rights; and (2) the postconviction court did not err when it struck the testimony the witness gave before invoking his Fifth Amendment privilege. View "Caldwell v. State" on Justia Law

After a jury trial, Defendant was found guilty of first-degree premeditated murder, second-degree intentional murder, and second-degree felony murder. The district court sentenced Defendant, who was eighteen years old at the time he committed the offense, to life in prison without the possibility of release for the first-degree premeditated murder conviction. The Supreme Court affirmed as modified, holding (1) the district court did not err when it denied Defendant’s motion to suppress his confessions because the confessions were voluntary; (2) Defendant forfeited his claim that his mandatory sentence of life imprisonment without the possibility of release violates the Eighth Amendment prohibition on cruel and unusual punishment because he was psychologically and socially a juvenile when he committed the crime; and (3) because the order attached to the Warrant of Commitment incorrectly listed convictions for the two lesser-included offenses, those two convictions are vacated. View "State v. Nelson" on Justia Law

After a jury trial, Defendant was convicted of one count of first-degree premeditated murder and two counts of attempted first-degree premeditated murder. The Supreme Court affirmed the convictions on appeal. Defendant later filed a petition for postconviction relief, arguing that appellate counsel was ineffective for failing to raise several issues on appeal. The postconviction court denied the petition without holding an evidentiary hearing. The Supreme Court affirmed, holding that Defendant could not show prejudice from his appellate counsel’s alleged errors, and therefore, the postconviction court did not abuse its discretion by denying Defendant’s postconviction motion without holding an evidentiary hearing. View "Morrow v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree premeditated murder and other crimes. Defendant was sentenced to life imprisonment without the possibility of release. Defendant appealed, asserting a number of errors. The Supreme Court affirmed, holding (1) there was sufficient evidence to support Defendant’s convictions; (2) the district court did not commit reversible error when it disallowed certain defense evidence offered at trial; (3) Defendant was not denied the effective assistance of trial counsel; (4) Defendant was not entitled to a sentencing hearing under Miller v. Alabama; and (5) Defendant’s claims offered in a pro se supplemental brief lacked merit. View "State v. Robertson" on Justia Law

After a jury trial, Appellant was found guilty of one count of first-degree murder of a peace officer, three counts of attempted first-degree murder of a peace officer, and one count of unauthorized possession of a firearm. The Supreme Court affirmed, holding (1) the district court did not violate Defendant’s right under the Minnesota Constitution to be tried by a jury of the county or district in which the alleged offense occurred; and (2) the district court did not commit prejudicial error by refusing to sever the first-degree murder charge from the other charges in Appellant’s case for the purpose of trial. View "State v. Fitch" on Justia Law