Justia Civil Rights Opinion Summaries
Articles Posted in Minnesota Supreme Court
State v. Horst
After a jury trial, Defendant was convicted of first-degree premeditated murder and sentenced to life imprisonment without the possibility of release. The Supreme Court affirmed the conviction, holding (1) the district court did not err when it denied Defendant’s motion to suppress statements from a police interview conducted shortly after the murder; (2) the warrantless seizure of Defendant’s cellphone did not violate her constitutional rights; (3) Defendant was not entitled to relief on her claim that defective search warrants violated her constitutional rights; (4) the district court did not err when it failed to give an accomplice-corroboration jury instruction; (5) the district court did not err in denying Defendant’s request to remove a juror for cause; and (6) the evidence was sufficient to support Defendant’s conviction of first-degree premeditated murder. View "State v. Horst" on Justia Law
State v. Morse
Respondent was pulled over by a police office on suspicion of driving while impaired for taking a wide right turn and weaving once within his lane around 2 a.m. Respondent was arrested and subsequently charged with second degree driving while impaired. Respondent moved to dismiss the charges, arguing that the arresting officer lacked a valid basis for the traffic stop. The trial court denied the motion to dismiss. Respondent was subsequently found guilty of one count of second-degree driving while impaired-alcohol concentration of 0.08 or more within two hours. The court of appeals reversed, concluding that the stop was improper. The Supreme Court reversed, holding that, under the totality of the circumstances, the arresting officer had a reasonable, articulable suspicion to justify the vehicle stop. View "State v. Morse" on Justia Law
State v. Lester
After a bench trial, Defendant was convicted of third-degree possession of a controlled substance. Defendant appealed, arguing that the district court erred by denying his motion to suppress the heroin seized from the car he was driving on the grounds that the police unlawfully searched the car without a warrant. The court of appeals reversed, concluding that the police did not have probable cause to arrest Defendant or to search his car. The Supreme Court reversed, holding that the warrantless search of Defendant’s car was lawful under the automobile exception because there was probable cause to believe that Defendant’s car contained contraband, and therefore, the district court properly denied Defendant’s motion to suppress. View "State v. Lester" on Justia Law
State v. Lester
After a bench trial, Defendant was convicted of third-degree possession of a controlled substance. Defendant appealed, arguing that the district court erred by denying his motion to suppress the heroin seized from the car he was driving on the grounds that the police unlawfully searched the car without a warrant. The court of appeals reversed, concluding that the police did not have probable cause to arrest Defendant or to search his car. The Supreme Court reversed, holding that the warrantless search of Defendant’s car was lawful under the automobile exception because there was probable cause to believe that Defendant’s car contained contraband, and therefore, the district court properly denied Defendant’s motion to suppress. View "State v. Lester" on Justia Law
State v. Peltier
After a jury trial, Appellant was found guilty of first-degree murder while committing child abuse, second-degree felony murder, and second-degree manslaughter. The district court imposed a life sentence with eligibility for supervised release after thirty years. The Supreme Court affirmed the conviction, holding (1) the jury instruction describing felony malicious punishment of a child as a type of child abuse was plainly erroneous, but Appellant failed to establish that the erroneous jury instruction affected her substantial rights; (2) assuming that the district court abused its discretion when it allowed a state expert to testify that biting a child is a “particularly vicious” form of child abuse, there was no reasonable likelihood that the testimony significantly affected the verdict in this case; and (3) the prosecutor made improper remarks during closing argument, but the prosecutorial misconduct did not affect Appellant’s substantial rights. View "State v. Peltier" on Justia Law
State v. Peltier
After a jury trial, Appellant was found guilty of first-degree murder while committing child abuse, second-degree felony murder, and second-degree manslaughter. The district court imposed a life sentence with eligibility for supervised release after thirty years. The Supreme Court affirmed the conviction, holding (1) the jury instruction describing felony malicious punishment of a child as a type of child abuse was plainly erroneous, but Appellant failed to establish that the erroneous jury instruction affected her substantial rights; (2) assuming that the district court abused its discretion when it allowed a state expert to testify that biting a child is a “particularly vicious” form of child abuse, there was no reasonable likelihood that the testimony significantly affected the verdict in this case; and (3) the prosecutor made improper remarks during closing argument, but the prosecutorial misconduct did not affect Appellant’s substantial rights. View "State v. Peltier" on Justia Law
State v. Whitson
After a jury trial, Defendant was found guilty of first-degree felony murder and attempted first-degree premeditated murder. Defendant was sentenced to life in prison for the murder. The Supreme Court stayed Defendant’s appeal so he could pursue postconviction relief. The district court denied Defendant’s petition for postconviction relief without holding an evidentiary hearing. On appeal, Defendant alleged the same five errors that he raised in his postconviction petition and argued that the postconviction court erred by denying his petition without granting an evidentiary hearing. The Supreme Court affirmed Defendant’s convictions and the summary denial of Defendant’s petition for postconviction relief, holding (1) Defendant was not entitled to a new trial on any of his claims; and (2) the postconviction court did not abuse its discretion in denying Defendant’s petition without a hearing. View "State v. Whitson" on Justia Law
State v. Smith
After a jury trial, Defendant was found guilty of two counts of second-degree murder and two counts of first-degree premeditated murder. Defendant was sentenced to two concurrent life sentences without the possibility of release. After a restitution hearing, the district court denied the victims’ families’ requests for restitution to cover the estimated cost of a headstone for each victim. The Supreme Court affirmed Defendant’s first-degree murder convictions and reversed the district court on the issue of restitution, holding that the district court (1) did not commit reversible error when it denied Defendant’s motion to dismiss the indictment for individual and cumulative errors; (2) did not violate Defendant’s Sixth Amendment right to a public trial when it closed the courtroom to the public to discuss its written order on the admissibility of certain testimony; (3) did not commit prejudicial error in excluding four pieces of evidence; (4) did not commit misconduct in his closing argument; and (5) erred by allowing Defendant to challenge the restitution request for the headstones under Minn. Stat. 611A.045(3)(a). View "State v. Smith" on Justia Law
State v. Little
The State filed a complaint against Defendant charging him with third- and fourth-degree criminal sexual conduct. Defendant waived his right to a jury trial during a pretrial hearing. Thereafter, the State filed an amended complaint adding a charge of first-degree criminal sexual conduct. Defendant did not personally waive his right to a jury trial on the amended charge. Defendant was subsequently found guilty of all three counts. Defendant appealed, arguing that the district court erred when it failed to obtain a personal waiver of his right to a jury trial after the State amended the complaint. The court of appeals affirmed Defendant’s first-degree sexual conduct conviction. The Supreme Court reversed the court of appeals, vacated Defendant’s conviction for first-degree criminal sexual conduct, and remanded, holding (1) when the State charges a defendant with an additional offense after the defendant has waived his or her right to a jury trial, the court must obtain a new waiver before dispensing with a jury; and (2) in this case, the district court’s failure to obtain a personal waiver of Defendant’s right to a jury trial on the charge of first-degree criminal sexual conduct constituted a plain error that affected Defendant’s substantial rights. View "State v. Little" on Justia Law
State v. Rossberg
Appellant was convicted for the first-degree premeditated murder of Devan Hawkinson. Appellant and Hawkinson were friends before Hawkinson was murdered. On appeal, Appellant argued that the district court erred by admitting evidence of his past conduct and relationship with Hawkinson, contending that the evidence violated his rights under the Confrontation Clause because it included testimonial statements that Hawkinson made to the police before his death and that it was irrelevant. The Supreme Court affirmed, holding (1) any error in admitting the evidence was harmless; and (2) none of the claims raised in Appellant’s pro se briefs entitled him to relief. View "State v. Rossberg" on Justia Law