Justia Civil Rights Opinion Summaries
Articles Posted in Minnesota Supreme Court
State v. McDonald-Richards
Appellant was convicted of aiding and abetting first-degree murder and aiding and abetting attempted first-degree murder. Appellant appealed, arguing that the district court committed reversible error in admitting a statement she made to police as the fruit of an unlawful arrest in violation of the Fourth Amendment. The Supreme Court affirmed, holding (1) the trial court erred in admitting Appellant's statement to police because the taint of Appellant's unlawful arrest was not purged at the time Appellant made her statement, and therefore, the statement was inadmissible; but (2) the trial court's error in admitting this statement was harmless beyond a reasonable doubt. View "State v. McDonald-Richards" on Justia Law
Sawh v. City of Lino Lakes
This case arose out of three biting incidents involving a dog owned by Respondent. After the first bite, the City of Lino Lakes designated Respondent's dog as "potentially dangerous," and after the second bite, the City designated the dog as "dangerous." After the third bite, the City ordered the dog to be destroyed. The court of appeals reversed the City's decisions, holding that Appellant's inability to challenge the "potentially dangerous" designation violated his right to procedural due process. The Supreme Court reversed the decision of the court of appeals, upheld the City's designation of the dog as "dangerous," and affirmed the City's order to destroy the dog, holding (1) Respondent was not constitutionally entitled to a hearing to challenge the "potentially dangerous" designation; and (2) substantial evidence supported the City's decisions. View "Sawh v. City of Lino Lakes" on Justia Law
State v. Scruggs
A jury found Appellant guilty of first-degree premeditated murder and second-degree intentional murder. The Supreme Court affirmed, holding that the district court did not err in (1) denying Appellant's motion to suppress his statement to police, as Appellant was not in custody or under arrest when the statement was made; (2) refusing to instruct the jury that Appellant's girlfriend, H.J., was an accomplice as a matter of law, as the issue of whether H.J. was an accomplice was a fact question for the jury; (3) failing to instruct the jury on the aiding-and-advising theory of accomplice liability; and (4) admitting evidence of Appellant's prior assaults of H.J. View "State v. Scruggs" on Justia Law
State v. R.H.B.
Appellant was charged with first- and third-degree on the ground that Appellant injured a young child in his care. A jury found Appellant not guilty of both charges, and the district court entered a judgment of acquittal. Appellant then petitioned the district court for an order sealing the criminal records related to the alleged assault. The district court granted Appellant's petition, concluding that the State failed to prove by clear and convincing evidence that the public's interests outweighed Appellant's interests pursuant to Minnesota's expungement statute. The court of appeals reversed, finding that Appellant proved no specific disadvantage to himself against which to balance the interests of the public. The Supreme Court reversed the decision of the court of appeals, holding that an expungement petitioner is not required to prove specific disadvantages he or she will suffer if the petition is denied and may instead satisfy his or her burden of production simply by establishing the fact of his or her acquittal. View "State v. R.H.B." on Justia Law
Lussier v. State
Appellant pled guilty to first-degree murder while committing domestic abuse and was sentenced to life imprisonment with the possibility of parole. Defendant did not appeal but subsequently filed a postconviction petition, alleging that his guilty plea was invalid because it lacked a proper factual foundation. The postconviction court denied relief on the ground that the petition was untimely and lacked substantive merit. The Supreme Court affirmed, holding (1) because there was sufficient evidence of a past pattern of domestic abuse and sufficient evidence of an extreme indifference to human life, Appellant's claim that he was entitled to withdraw his plea failed on the merits, and therefore, Appellant failed to establish a manifest injustice entitling him to withdraw his guilty plea; and (2) therefore, the Court did not need to reach the remaining issues raised in this appeal. View "Lussier v. State" on Justia Law
State v. Hokanson
Appellant was found guilty by a jury of first-degree murder while committing malicious punishment of a child with a past pattern of child abuse for the death of his seventeen-month-old stepson. The supreme Court affirmed Appellant's conviction, holding (1) the district court did not abuse its discretion or violate Appellant's right to present an alternative perpetrator defense in limiting access to social services records; (2) the district court did not err in ruling that potential reverse-Spreigl evidence was inadmissible or violate Defendant's right to present an alternative perpetrator defense in doing so; (3) the State presented sufficient evidence to prove the element of a past pattern of child abuse beyond a reasonable doubt; (4) the jury instructions on the element of a past pattern of child abuse fairly and correctly stated the applicable law; and (5) Defendant's defense counsel did not engage in ineffective assistance of counsel by failing to object to the jury instructions, as the jury instructions given were not erroneous. View "State v. Hokanson" on Justia Law
Wallace v. State
Following a jury trial, Appellant was convicted of first-degree felony murder, attempted second-degree criminal sexual conduct, and second-degree assault. The Supreme Court affirmed the convictions. Fourteen years later, Appellant filed his second petition for postconviction relief, which the postconviction court summarily denied as untimely filed. Appellant appealed, contending that his petition should be considered because it was not frivolous and was in the interests of justice pursuant to Minn. Stat. 590.01, 4(b) The Supreme Court affirmed, holding that Appellant's postconviction claims were time-barred under section 590.01, 4, and that Appellant's petition failed to satisfy the interests-of-justice exception in Minn. Stat. 590.01, 4(b)(5) because each of the claims in the petition was frivolous. View "Wallace v. State" on Justia Law
State v. Milton
After a jury trial, Defendant was convicted of one count of first-degree felony murder and one count of attempted first-degree felony murder. The Supreme Court affirmed Defendant's convictions, holding (1) the district court did not err by refusing to suppress shell casings seized from the back stairway of Defendant's multifamily residence, as their seizure satisfied the plain-view exception to the presumptive rule against warrantless seizures; (2) the State did not commit prosecutorial misconduct when it referenced shell casings found in Defendant's truck; (3) the district court plainly erred when it failed to instruct the jury that, in order to find Defendant guilty of attempted first-degree felony murder, the jury had to find Defendant intentionally aided his alleged accomplices in the commission of the crime, but this error did not warrant the grant of a new trial. View "State v. Milton" on Justia Law
State v. Cox
After a jury trial, Defendant was convicted of first-degree felony murder, second-degree intentional murder, and being a prohibited person in possession of a firearm for the shooting death of a cab driver. The district court sentenced Defendant to life imprisonment on the first-degree felony murder conviction and to a sixty-month concurrent sentence on the firearm conviction but did not sentence Defendant on the second-degree intentional murder conviction. The Supreme Court vacated Defendant's second-degree intentional murder conviction but otherwise affirmed Defendant's convictions, holding (1) the district court did not err when it declined Defendant's request for a jury instruction on accomplice testimony; (2) the district court did not abuse its discretion when it instructed the jury to continue deliberating after the jury indicated it was deadlocked; and (3) the district court erred by convicting Defendant of both first- and second-degree murder because second-degree intentional murder is a lesser-included offense of first-degree murder. View "State v. Cox " on Justia Law
State v. Davis
Appellant was convicted of aiding and abetting first-degree felony murder. The district court sentenced Appellant to life in prison. On appeal, Appellant claimed that numerous errors entitled him to a new trial. The Supreme Court affirmed Appellant's conviction, holding (1) the jury's verdict was unattributable to any error in admitting Appellant's statement recorded after he allegedly invoked his right to remain silent, and therefore, the admission of the statement into evidence was harmless; (2) the district court did not plainly err by allowing fear testimony at trial; (3) the district court did not abuse its discretion by not admitting certain hearsay statements; (4) the district court did not plainly err by giving a no-adverse-inerence jury instruction without Appellant's clear consent; and (5) Appellant was not entitled to a new trial based on the cumulative effect of the district court's errors. View "State v. Davis" on Justia Law