Justia Civil Rights Opinion Summaries

After a jury trial, Appellant was convicted of first-degree felony murder while committing a drive-by shooting for the benefit of a gang. The Supreme Court stayed Appellant’s direct appeal to permit Appellant to file a petition for postconviction relief. The postconviction court subsequently denied relief. The Supreme Court consolidated Appellant’s direct and postconviction appeals into a single proceeding and held (1) the record contained sufficient evidence to support Appellant’s conviction; (2) some of the individual jury instructions in this case were erroneous, but the jury instructions, considered as a whole, did not constitute reversible error; (3) Appellant knowingly and voluntarily waived his right to testify at trial; (4) Appellant was not deprived of his right to the effective assistance of trial counsel; (5) the district court did not abuse its discretion when it denied Appellant’s motion for a mistrial; (6) the jury did not return legally inconsistent verdicts; and (7) the postconviction court did not err when it denied an evidentiary hearing on Appellant’s claim that the district court violated his right to a public trial. View "State v. Bahtuoh" on Justia Law

Defendant was convicted of first-degree murder and sentenced to life imprisonment. The Supreme Court affirmed the conviction on direct appeal. Defendant subsequently filed several petitions for postconviction relief. Defendant's fourth petition for postconviction relief alleged that new evidence, an unsworn statement by an alleged eyewitness to the murder, entitled him to a new trial. After an evidentiary hearing, the postconviction court denied Defendant's fourth petition for postconviction relief. The Supreme Court affirmed, holding that the postconviction court (1) did not err in denying Defendant a new trial based on new evidence; (2) did not abuse its discretion in how it handled evidence that Defendant submitted after the evidentiary hearing; and (3) did not err in refusing to grant relief in the interests of justice. View "Miles v. State" on Justia Law

After a jury trial, Defendant was convicted of two counts of felony violation of a domestic abuse no-contact order. The court of appeals reversed and remanded for a new trial, holding (1) the failure to instruct on an element of the charged offense as a matter of law affects a defendant's substantial rights, and (2) Defendant's substantial rights were affected as a matter of law by the district court's failure to instruct the jury on the "knowingly" element of the charged offense. The Supreme Court affirmed but on different grounds, holding (1) an unobjected-to jury instruction that omits an element of the charged offense does not, as a matter of law, affect a defendant's substantial rights, but rather, the trial court must consider certain factors to determine whether the omission of an element of a charged offense from the instruction to the jury was sufficiently prejudicial to warrant a new trial; and (2) the trial court's failure to instruct on the "knowingly" element of the charged offense was an error that affected Defendant's substantial rights. View "State v. Watkins" on Justia Law

Defendant was charged with first-degree premeditated murder for the benefit of a gang. Defendant was acquitted of the first-degree murder offense but convicted of the lesser-included offense of second-degree intentional murder for the benefit of a gang. The Supreme Court vacated the second-degree murder conviction on appeal. On remand, a second grand jury indicted Defendant with first-degree felony murder for the benefit of a gang and second-degree intentional murder for the benefit of a gang. After Defendant unsuccessfully filed a motion to dismiss the felony murder charge on the grounds that the charge violated constitutional and statutory prohibitions against double jeopardy, Defendant was found guilty of the first-degree felony murder and second-degree intentional murder charges. The trial court convicted Defendant on the second-degree murder offense. The Supreme Court (1) affirmed the conviction of second-degree intentional murder for the benefit of a gang, holding that the State presented sufficient evidence to support the conviction; and (2) reversed the district court's denial of Defendant's pretrial motion to dismiss, holding that the court failed properly to analyze the double jeopardy issue. View "State v. Chavarria-Cruz" on Justia Law

After a jury trial, Respondent was convicted of third-degree criminal conduct in violation of Minn. Stat. 609.344(1)(l)(i) (the clergy-sexual-conduct statute) based on a sexual relationship between Respondent, a Roman Catholic priest, and a parishioner. The court of appeals reversed, holding (1) the clergy-sexual-conduct statute is not facially unconstitutional; but (2) the statute violated the Establishment Clause as applied to Respondent. the Supreme Court affirmed in part and reversed in part, holding (1) the clergy-sexual-conduct statute does not facially violate the Establishment Clause; and (2) Respondent did not prove that the clergy-sexual-conduct statute as applied violated the Establishment Clause. Remanded. View "State v. Wenthe" on Justia Law

After a jury trial, Appellant was convicted of three counts of first-degree murder and sentenced to three concurrent sentences of life imprisonment with the possibility of release. Appellant subsequently filed three petitions for postconviction relief, all of which were denied. This appeal involved Appellant's third petition for postconviction relief in which Appellant alleged he was entitled to a new trial based on newly discovered evidence. The Supreme Court affirmed, holding (1) the postconviction court did not abuse its discretion when it concluded that Appellant was not entitled to a new trial based on newly discovered evidence; and (2) the chief judge of the district court did not abuse his discretion when he denied Appellant's motion to remove all current and former judges of the Fourth Judicial District for cause. View "Hooper v. State" on Justia Law

In each of three separate incidents, the State charged Defendant with two counts of first-degree driving while impaired. Defendant moved to suppress the results of blood and urine tests in each case because law enforcement officers took the samples without a warrant. The district courts denied Defendant's request to suppress the test results, concluding (1) the evanescent quality of alcohol in Defendant's body created exigent circumstances that excused police from seeking a warrant to obtain the urine tests; and (2) Defendant consented to the blood test. The district courts subsequently convicted Defendant of first-degree driving while impaired. The Supreme Court vacated the judgments and remanded for further consideration in light of Missouri v. McNeely. Following remand, the court of appeals reinstated Defendant's appeals. The Supreme Court affirmed Defendant's convictions, holding that, based on the totality of the circumstances, Defendant consented to the search, and therefore, police did not need a warrant to search Defendant's blood or urine. View "State v. Brooks" on Justia Law

Respondent was charged with criminal sexual conduct in the fourth and fifth degree. Respondent agreed to conduct a trial on stipulated facts pursuant to Minn. R. Crim. P. 26.01(3) and waived all trial rights. The district court found Respondent guilty of criminal sexual conduct in the fifth degree. Respondent subsequently filed a petition for postconviction relief, contending that he was entitled to a new trial because the procedure used to convict him was not a trial on stipulated facts pursuant to Rule 26.01(3) and because he received ineffective assistance of counsel. The court of appeals reversed Respondent's conviction on the grounds that Respondent's trial counsel failed to subject the prosecution's case to meaningful adversarial testing. The Supreme Court reversed, holding (1) it was not error for the parties to conduct a bench trial consistent with the provisions of Rule 26.01(2) even though the parties characterized the trial as a stipulated-facts trial under Rule 26.01(3); and (2) Respondent received ineffective assistance of counsel where defense counsel did not entirely fail to subject the prosecution's case to meaningful adversarial testing. View "Dereje v. State" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder in the course of a burglary and sentenced to life imprisonment. Appellant subsequently filed a petition for postconviction relief, alleging that he was entitled to a new trial based on newly discovered evidence. Specifically, Appellant alleged that Tracy Sailor, one of the people who was with Appellant at the time of the murder, had made statements indicating that Sailor killed the victim and that Sailor's statements were both newly discovered evidence that Sailor was the victim's killer and a recantation of Sailor's trial testimony that Appellant killed the victim. The postconviction court denied Appellant a new trial. The Supreme Court affirmed, holding that the postconviction court did not abuse its discretion by denying Appellant a new trial. View "Torres v. State " on Justia Law

Following a court trial, Appellant was convicted of first-degree criminal sexual conduct, second-degree criminal sexual conduct, kidnapping, and third-degree assault. Upon sentencing Appellant, the district court found that Appellant met the requirements of Minn. Stat. 609.3455(2)(a), which provides for mandatory life imprisonment without the possibility of release for certain aggravated sex crimes, and sentenced Appellant to life imprisonment without the possibility of release on the charge of second-degree criminal sexual conduct. The court of appeals affirmed. Appellant appealed, contending, among other things, that section 609.3455 as applied imposed cruel and unusual punishment in violation of the federal and state constitutions. The Supreme Court affirmed, holding that the imposition of life imprisonment without the possibility of release was not cruel or unusual punishment for Appellant's aggravated criminal sexual conduct. View "State v. Juarez" on Justia Law