Justia Civil Rights Opinion Summaries

Defendant was convicted in 1990 of first-degree premeditated murder. The Supreme Court affirmed the conviction on direct appeal. Defendant subsequently filed a petition for postconviction relief requesting an evidentiary hearing to consider evidence he asserted was new and exculpatory. Specifically, Defendant sought a hearing to consider (1) newly discovered eyewitness testimony, which he claimed buttressed his alternative-perpetrator theory, and (2) whether he was entitled to have DNA testing of a sample from a smear found at the crime scene. The postconviction court denied Defendant's petition and motion without an evidentiary hearing, concluding that Defendant did not meet the standard for receiving an evidentiary hearing. The Supreme Court affirmed, holding that Defendant failed to meet the threshold required for relief, and thus, the postconviction court did not abuse its discretion when it denied Defendant's motion without an evidentiary hearing. View "Fort v. State" on Justia Law

After a jury trial, Appellant was found guilty of first-degree premeditated murder. On appeal, the Supreme Court affirmed the conviction. Appellant subsequently filed a petition for postconviction relief alleging seven separate grounds he contended warranted a new trial. The postconviction court summarily denied Appellant's petition, explaining that Appellant's claims were either meritless on their face or barred by State v. Knaffla. The Supreme Court affirmed, holding that the postconviction court properly determined that the petition and files and records of the trial conclusively showed Appellant was not entitled to postconviction relief because his claims were either meritless on their face or barred by the Knaffla rule. View "Anderson v. State" on Justia Law

Defendant was convicted for first-degree murder and attempted first-degree murder. After Defendant's convictions were affirmed on appeal, Defendant filed four separate petitions for postconviction relief, each of which was denied by the postconviction court. Defendant filed a fifth petition for postconviction relief, arguing that (1) he was entitled to relief based on newly discovered evidence of false testimony, and (2) the statute under which he was convicted was unconstitutional. The postconviction court denied Defendant's petition. The Supreme Court affirmed, holding (1) based on the postconviction court's findings, the court did not abuse its discretion when it summarily denied Defendant's claim of newly discovered evidence; and (2) Defendant's claim that the statute under which he was convicted was unconstitutional was time-barred. View "McDonough v. State" on Justia Law

A jury found Defendant guilty of first-degree felony murder while committing a drive-by shooting and second-degree intentional murder. The district court convicted Defendant of first-degree felony murder and sentenced him to life imprisonment with the possibility of release. The Supreme Court reversed Defendant's conviction of first-degree felony murder while committing a drive-by shooting, holding (1) the State did not present sufficient evidence to support Defendant's conviction because Defendant's conduct in this case did not meet the definition of a drive-by shooting; and (2) the district court did not err when it admitted testimony at trial that a witness was threatened and attacked for being a "snitch." Remanded with instructions to enter a judgment of conviction on the second-degree intentional murder count. View "State v. Hayes" on Justia Law

After a jury trial, Appellant was convicted of possessing a firearm as an ineligible person in violation of Minn. Stat. 624.713(1)(2), which prohibits a person previously convicted of a crime of violence from possessing a firearm. After trial, Appellant unsuccessfully moved to vacate his conviction on the basis that the statute, as applied to him, violated the Second Amendment. The court of appeals upheld the statute as constitutional and affirmed Appellant's conviction. The Supreme Court affirmed, albeit on different grounds, holding that application of section 624.713(1)(2) to Appellant did not violate the Second Amendment as historically understood, because the Second Amendment as understood at the time of its ratification excluded those convicted of crimes of violence from exercising the right to possess a firearm. View "State v. Craig" on Justia Law

After a jury trial, Appellant was convicted of aiding and abetting the first-degree murder of his brother as well as obstructing an investigation. Appellant was sentenced to life in prison without the possibility for parole. Appellant subsequently filed a petition for postconviction relief, which the postconviction court denied. The Supreme Court affirmed, holding (1) Appellant's ineffective-assistance-of-counsel claim failed because Appellant failed to show that, but for his attorneys' alleged errors, there was a reasonable probability the outcome of his trial would have been different; and (2) any error in the admission of statements made by Appellant's sister and girlfriend was harmless beyond a reasonable doubt. View "Hawes v. State" on Justia Law

Following a jury trial, Appellant was convicted of first-degree premeditated murder and attempted first-degree premeditated murder. After Appellant's first petition for postconviction relief was denied, Appellant filed a second postconviction petition. After a hearing, the postconviction court denied Appellant's petition. Appellant appealed, contending (1) the postconviction court erred in concluding that an affidavit from a recanting witness is inadmissible hearsay, and (2) he was denied the effective assistance of counsel during the postconviction proceedings. The Supreme Court affirmed, holding (1) the postconviction court did not abuse its discretion in excluding the affidavit, as Appellant failed to establish corroborating circumstances clearly indicating the trustworthiness of Appellant's affidavit; and (2) Appellant did not have a constitutional right to effective assistance of postconviction counsel, and therefore, his ineffective-assistance-of-counsel claim failed as a matter of law. View "Ferguson v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree premeditated murder and attempted first-degree murder. Defendant was sentenced to life imprisonment. The Supreme Court affirmed Defendant's convictions on direct appeal. Defendant filed a petition for habeas corpus relief in federal district court, which was denied, and a petition for postconviction relief in state court, which was also denied. Defendant subsequently filed a second petition for postconviction relief, which the postconviction court denied after concluding that the petition was filed after the expiration of the two-year limitations period in Minn. Stat. 590.01, subd. 4(a)(2). The Supreme Court affirmed, holding that the district court did not abuse its discretion in denying the petition as untimely, as the petition satisfied neither exception to the limitations period. View "Berkovitz v. State" on Justia Law

After a jury trial, Appellant was convicted of aiding and abetting first-degree premeditated murder and sentenced to life in prison without the possibility of release. The Supreme Court affirmed Appellant's conviction and sentence. Appellant subsequently filed a petition for postconviction relief alleging seven claims. The postconviction court summarily denied the petition without a hearing. The Supreme Court affirmed in part, reversed in part, and remanded, holding (1) the postconviction court erred in denying Appellant's request for an evidentiary hearing on his claim of witness recantation; but (2) the postconviction court did not err in finding Appellant's ineffective-assistance-of-counsel claim to be without merit and in concluding that Appellant's remaining claims were barred by State v. Knaffla. View "Martin v. State" on Justia Law

Appellant, an enrolled member of the Leech Lake Band of Ojibwe, was civilly committed to the Minnesota Sex Offender Program (MSOP). Appellant appealed, challenging his indeterminate civil commitment by asserting three substantive claims. The Supreme Court affirmed, holding (1) the district court had jurisdiction to indeterminately civilly commit an enrolled member of the Leech Lake Band of Ojibwe; (2) the doctrines of collateral estoppel and res judicata did not preclude the State from presenting in the civil commitment proceeding evidence of conduct alleged in earlier criminal cases that ended in acquittals; and (3) Appellant waived his to right appellate review of his claim that the State violated the Minnesota Constitution when it committed him without a trial by jury. View "Beaulieu v. Dep't of Human Servs." on Justia Law