Justia Civil Rights Opinion Summaries

After a jury trial, Appellant was convicted of first-degree premeditated murder and second-degree murder. Appellant appealed, asserting, among other issues, that the trial court erred in denying his motion to suppress statements he made to police because he was in custody when he made the statements and had not received a Miranda warning. The Supreme Court affirmed Defendant's convictions, holding (1) any error the trial court may have made in denying Appellant's motion to suppress statements he made to police was harmless beyond a reasonable doubt; and (2) the evidence was sufficient to support Appellant's conviction. View "State v. Sterling" on Justia Law

The district court issued domestic abuse no contact orders pursuant to Minn. Stat. 629.75(1) prohibiting Appellant from contacting his wife. After Appellant allegedly contacted his wife, he was charged with two felony violations. Appellant moved to dismiss the charges, contending that section 629.75(1) violates due process because it fails to provide adequate notice and an opportunity to be heard and encourages arbitrary and discriminatory enforcement. The district court granted Appellant's motions, concluding that the statute provides defendants with no procedural due process and grants judges unfettered discretion in determining whether to issue a domestic abuse no contact order. The court of appeals reversed. The Supreme Court affirmed, holding that, on its face, the statute (1) ensures that a defendant will receive notice of the conditions to be imposed and an opportunity to challenge those conditions in a constitutionally sufficient proceeding before the court imposes a domestic abuse no contact order; and (2) is not unconstitutionally vague because it does not encourage arbitrary and discriminatory enforcement. View "State v. Ness" on Justia Law

The State charged Defendant with two counts of second-degree murder for the stabbing death of Tina San Roman and second-degree assault and attempted second-degree murder for the stabbing of a second victim, O.A.R. A jury acquitted Defendant on the murder counts but deadlocked on the two other counts relating to the attack on O.A.R. In preparation for a retrial on the unresolved counts, the district court (1) excluded the State's evidence related to San Roman's death, concluding that the evidence would mislead the jury and substantially prejudice Defendant; then (2) granted Defendant's motion to dismiss the remaining counts, concluding (i) Defendant could not present his alternative-perpetrator defense without using evidence relating to San Roman's death, and (ii) the exclusion of Defendant's alternative-perpetrator evidence would violate Defendant's right to present a complete defense. The Supreme Court reversed and remanded, holding that the exclusion of the alternative-perpetrator evidence did not violate Defendant's due process right to present a complete defense. View "State v. Pass " on Justia Law

Appellant was convicted of murder and sentenced to life in prison. The Supreme Court affirmed the conviction. After unsuccessfully filing four petitions for postconviction relief, Appellant filed a "Motion for DNA Analysis" under Minn. Stat. 590.01(1)(a) requesting DNA testing of the victim's underwear. The postconviction court construed Appellant's motion as his fifth petition for postconviction relief and found the petition was procedurally barred. The Supreme Court affirmed without addressing the issue of whether the postconviction court erred when it treated Appellant's motion as a petition for postconviction relief, holding (1) Appellant's motion for DNA testing failed to satisfy the requirements of Minn. Stat. 590.01(1)(a) as a matter of law; and (2) even if it was proper to treat Appellant's motion as a petition for postconviction relief, Appellant's claim was time-barred. View "Wayne v. State" on Justia Law

After a jury trial, Defendant was convicted of two counts of first-degree premeditated murder, first-degree arson, and theft of a motor vehicle. The district court sentenced Defendant to two consecutive life sentences without the possibility of parole for the two first-degree premeditated murder convictions. The Supreme Court affirmed, holding (1) the district court's removal of two persons from the courtroom during voir dire did not violate Defendant's right to a public trial; (2) the district court erred when it admitted a statement Defendant made to the police during an unlawful search, but the error was harmless; (3) the district court did not abuse its discretion when it admitted into evidence several items that were found when Defendant was arrested; and (4) the district court did not abuse its discretion when it ruled that, if Defendant chose to testify at trial, the State could attempt to impeach him using three prior felony convictions. View "State v. Zornes" on Justia Law

After a jury trial, Appellant was convicted of first-degree premeditated murder and sentenced to life imprisonment without the possibility of release. The Supreme Court affirmed Appellant's conviction, holding (1) the record contained sufficient evidence to support the jury's verdict that Appellant, rather than an unidentified alternative perpetrator, was guilty of first-degree premeditated murder; and (2) based on State v. Brown and applying the factors set forth in State v. Lindsay, the trial court did not violate the public trial guarantees of the U.S. and Minnesota Constitutions by locking the courtroom doors before the State began its closing argument. View "State v. Silvernail" on Justia Law

Defendant was convicted of first-degree murder for the shooting death of Johanna Hollis and the attempted first-degree murder of Hollis's daughter. At trial, the State was only able to present a minimal amount of direct evidence connecting Defendant to the scene of the shooting. Thus, the State had to rely primarily on circumstantial evidence that included certain cellphone records. The records indicated that Defendant was in the vicinity of the shooting and supported the assertion by two witnesses that Defendant made threats to Hollis during a cellphone call Defendant placed to Hollis the night of the shooting. While Defendant's appeal was pending, a forensic expert conducted an examination of Defendant's cellphone. Defendant then petitioned for postconviction relief, alleging that the examination revealed Hollis could not have received the alleged threatening phone calls from Hollis's cellphone and that trial counsel provided ineffective assistance by failing to obtain Hollis's cellphone records and by failing to conduct a forensic examination of Hollis's cellphone. The postconviction court denied the petition without a hearing. The Supreme Court reversed, holding that Defendant met the threshold showing required to receive an evidentiary hearing on his ineffective-assistance-of-counsel claim. Remanded. View "State v. Nicks" on Justia Law

Defendant indicted of four counts of first-degree murder, one count of second-degree murder, and several related crimes arising out of the shooting death of his ex-wife and the kidnapping of their three children. Because Defendant pleaded not guilty by reason of mental illness, the district court bifurcated the trial. The jury found Defendant guilty of all counts and rejected his not-guilty-by-reason-of-mental-illness defense. The Supreme Court affirmed, holding that the district court (1) did not err by declining to remove a prospective juror for cause; (2) did not commit reversible error in making certain comments to the jury regarding the upcoming schedule of phase two of the trial; (3) may have erred in denying Defendant's request to testify on surrebuttal, but the error was harmless; (4) did not abuse its discretion when it determined that Defendant's nine-year-old daughter was incompetent to testify; and (5) did not abuse its discretion in failing to inquire into the nature of Defendant's pretrial complaints about counsel appointed to represent Defendant. In addition, the Court concluded that Defendant's pro se claims lacked merit. View "State v. Munt" on Justia Law

Defendant was found guilty of first-degree murder while committing domestic abuse with a past pattern of domestic abuse, and second-degree murder while committing a felony. The Supreme Court affirmed, holding (1) the State presented sufficient evidence to prove that Defendant assaulted the victim and caused his death; (2) the State presented sufficient evidence to prove Defendant had engaged in a past pattern of domestic abuse; (3) the district court did not err in failing to instruct the jury that a past pattern of domestic abuse requires proof beyond a reasonable doubt of at least two prior acts of abuse; and (4) the district court did not err in failing to instruct the jury that it needed to agree unanimously on which two specific acts of past abuse were proven beyond a reasonable doubt. View "State v. Hayes" on Justia Law

After a jury trial, Appellant was found guilty of first-degree murder and related charges. The district court sentenced Appellant on the first-degree murder conviction to a mandatory sentence of life imprisonment without the possibility of release. The Supreme Court affirmed Appellant's conviction and sentence on direct appeal. Appellant subsequently filed a second petition for postconviction relief, alleging that his sentence was unconstitutional under the Eighth Amendment. The postconviction court denied Appellant's petition without an evidentiary hearing, concluding that the petition was time barred and that none of the exceptions to the time bar applied. Appellant appealed, contending that his sentence violated the Eighth Amendment and that recent decisions of the U.S. Supreme Court satisfied an exception to the time bar. The Supreme Court affirmed, holding that the cases upon which Appellant relied were either not applicable to Appellant or did not apply retroactively to him. View "Chambers v. State" on Justia Law