Justia Civil Rights Opinion Summaries

After a jury trial, Appellant was convicted of two counts of aggravated forgery. The district court sentenced Appellant to twelve months in prison for each charge, to be served concurrently. Appellant appealed, challenging his convictions and sentence. Five days later, Appellant died. Appellant's counsel subsequently filed a motion to abate the prosecution ab initio. The court of appeals denied the motion and dismissed Appellant's direct appeal after deciding against adopting the abatement ab initio doctrine. The Supreme Court reversed the court of appeals' denial of the abatement motion and vacated Appellant's convictions, holding that when a defendant has taken an appeal from a final judgment of conviction in which no restitution was awarded and the accused is deprived of a decision on the merits because of his death, the prosecution should be abated ab initio. Remanded. View "State v. Burrell" on Justia Law

After a jury trial, Appellant was convicted of first-degree murder. The Supreme Court affirmed. Appellant subsequently filed a petition for postconviction relief, alleging, inter alia, that one of the witnesses who testified at Appellant's trial had given false testimony. The postconviction court denied the petition without an evidentiary hearing. The Supreme Court reversed and remanded for a hearing. After an evidentiary hearing on remand, the postconviction court again denied the petition, concluding that Appellant was not entitled to a new trial under the Larrison v. United States test. The Supreme Court affirmed, holding the postconviction court did not abuse its discretion when (1) it concluded that certain out-of-court statements by the witness were inadmissible hearsay; and (2) it denied Appellant's request for the appointment of advisory counsel to assist him at his postconviction evidentiary hearing. View "Dobbins v. State" on Justia Law

Respondent pleaded guilty to second-degree burglary and was placed on probation for five years. The district court also ordered Respondent to pay restitution in monthly payments. Near the expiration of Respondent's probation term, Respondent still owed $20,894 in restitution even though she had complied with the district court's payment schedule. After a hearing, the district court extended Respondent's probation for five years to facilitate continued payment of restitution. Respondent moved to amend the district court's order by reducing the extension to one year, arguing that the district court lacked the authority to extend her probation for five years because Minn. Stat. 609.135(2)(g) authorizes only two one-year extensions of probation based on the failure to pay restitution. The district court agreed and amended the extension of probation from five years to one year. The court of appeals affirmed. The Supreme Court reversed, holding that Minn. Stat. 609.135(1)(a) and Minn. Stat. 609.14 grant a district court authority to extend a term of probation up to the statutory maximum based on a defendant's failure to pay restitution by the end of the originally imposed probation term. Remanded. View "State v. Barrientos" on Justia Law

After a jury trial, Appellant was convicted of two counts of first-degree premeditated murder, two counts of first-degree felony murder, and three counts of first-degree aggravated robbery. The Supreme Court affirmed Appellant's convictions, holding that the district court did not err by (1) overruling Defendant's Batson objection to the State's peremptory challenge of an African-American prospective juror, as Defendant failed to prove that the challenge constituted purposeful racial discrimination; and (2) admitting evidence that Defendant assaulted and threatened a witness two days before trial to prove consciousness of guilt, as the district court correctly weighed the probative value of the evidence against the danger of unfair prejudice and provided safeguards to ensure the evidence would not unduly influence the jury's verdict. View "State v. Diggins" on Justia Law

Defendant, who was HIV positive, engaged in consensual anal intercourse. Defendant was subsequently charged with attempted first-degree assault by transferring a communicable disease for violating Minn. Stat. 609.2241(2). A jury found Defendant violated section 609.2241(2)(2), which applies to the "transfer of blood, sperm, organs, or tissue." The court of appeals reversed the conviction, concluding that section subdivision 2(2) applies only to medical procedures instead of applying to acts of sexual conduct. The Supreme Court affirmed, holding (1) subdivision 2(2) applies only to the donation or exchange for value of blood, sperm, organs, or tissue; and (2) because Defendant's conduct indisputably did not involve the donation or exchange for value of his sperm, subdivision 2(2) was inapplicable to Defendant's conduct. View "State v. Rick" on Justia Law

After a jury trial, Defendant was convicted of criminal vehicular homicide for causing the death of ninety-three-year-old Edith Schouveller in a motor vehicle accident. The accident occurred on March 28, 2010. Schouveller was transported to the hospital with several life-threatening injuries. For the next twenty-two days, Schouveller was either hospitalized or in a nursing home. Schouveller developed lung problems while in the hospital, which led to pneumonia. On April 19, 2010, Schouveller experienced acute respiratory failure. Doctors determined that she needed to be placed on a respirator in order to continue to live, but relying on Schouveller's living will, the doctors declined to place her on respiratory support. Schouveller died that evening. The Supreme Court affirmed Defendant's conviction, holding (1) the district court properly instructed the jury on causation; (2) the State presented sufficient evidence to demonstrate a causal chain between the injuries Shouveller sustained in the accident and the pneumonia and aspiration that ultimately led to her death; and (3) the evidence was sufficient for the jury to conclude that the do-not-resuscitate order in Souveller's living will was not a superseding cause of her death. View "State v. Smith" on Justia Law

After a jury trial in 1994, Defendant was convicted of first-degree murder and sentenced to life in prison with the possibility of release. Seven months later, Defendant pleaded guilty to second-degree attempted murder. The court sentenced Defendant to an additional seventy-two months in prison to run consecutively to his life sentence. In 2012, Defendant filed a pro se motion to correct his sentence under Minn. R. Crim. P. 27.03(9). The district court treated the motion as a petition for postconviction relief and then denied the motion on the grounds it was time barred and procedurally barred. The Supreme Court affirmed, holding that even if Defendant's motion was not time barred or procedurally, barred, his argument that the overall length of his imprisonment should be reduced failed on the merits. View "Townsend v. State" on Justia Law

After a jury trial, Defendant was convicted of nine counts, including one count of first-degree premeditated murder and two counts of attempted first-degree premeditated murder, stemming from an incident in which Defendant fired a semiautomatic rifle at Joseph Rivera and two of Rivera's friends. The Supreme Court affirmed, holding that the district court did not err when it (1) denied Defendant's pretrial motion to dismiss the indictment, as any alleged misconduct by the State did not substantially influence the grand jury's decision to indict; (2) admitted Defendant's taped statement to police, as the statement was voluntary made; (3) admitted a photograph of Rivera as a child, as the photograph was admissible as spark of life evidence; (4) denied Defendant's motion for a mistrial based on a law enforcement officer's testimony that Defendant was truant and once swore at a teacher in high school; and (5) denied Defendant's request for surrebuttal closing argument, because even if the district court erred in denying the request, the error was harmless beyond a reasonable doubt. View "State v. Morrow" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder by drive-by shooting and first-degree premeditated murder. Defendant appealed, arguing that the trial court erred in admitting out-of-court statements made by his wife and cell phone records obtained without a warrant. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion in admitting Defendant's wife's statement under Minn. R. Evid. 807; and (2) the district court did not err in finding Defendant had no subjective expectation of privacy in the cell phone records at issue under the Supreme Court's decision in State v. Gail, and therefore, the admission of the cell phone records did not violate Defendant's constitutional rights. View "State v. Griffin" on Justia Law

After a jury trial, Defendant was convicted of third-degree criminal sexual conduct and sentenced to forty-eight months in prison. As part of the sentencing order, the trial court ordered Defendant to pay restitution. More than ninety days after entry of the order imposing Defendant's initial sentence, the court amended the restitution portion of Defendant's initial sentence. The State appealed the amended sentencing order, but the court of appeals dismissed the appeal because it was not filed within ninety days after the initial imposition of Defendant's sentence. The Supreme Court reversed, holding (1) the issuance of an order amending the restitution portion of a sentence constitutes a "sentence imposed" within the plain language of the relevant statute, such that the State had ninety days to appeal the amended sentencing order from the date it was entered; and (2) because the State appealed the amended sentencing order within ninety days, the appeal was timely. Remanded. View "State v. Borg" on Justia Law