Justia Civil Rights Opinion Summaries

Appellant was arrested and charged with first-degree premeditated murder. At trial, Appellant admitted shooting the victim, but claimed he did so in self-defense and without premeditation. The jury, rejecting Appellant's self-defense claim, found Appellant guilty of first-degree premeditated murder, and the district court sentenced Appellant to life in prison without the possibility of release. Appellant thereafter filed a petition for postconviction relief, which the postconviction court denied. The Supreme Court affirmed Appellant's conviction and the postconviction court's denial of postconviction relief, holding that each of Appellant's claims was either without merit or did not result in prejudice to Appellant. View "State v. Radke" on Justia Law

Appellant was convicted of first-degree murder while committing a drive-by shooting and drive-by shooting. The Supreme Court affirmed Defendant's conviction. In this case, Defendant appealed the summary denial of his second petition for postconviction relief, which alleged a claim of ineffective assistance of appellate counsel, and his third petition for postconviction relief, which alleged a claim of newly discovered evidence. The Supreme Court (1) affirmed the postconviction court's summary denial of the second postconviction petition because the record conclusively showed appellate counsel was not ineffective; but (2) reversed the court's summary denial of the third postconviction petition and remanded for an evidentiary hearing because the record failed to conclusively show that Appellant was not entitled to relief based on his claim of newly discovered evidence.

Defendant was found guilty by a jury of three counts of first-degree murder and three counts of second-degree murder. The district court entered convictions on the three counts of first-degree murder and imposed three consecutive life sentences. The Supreme Court affirmed Defendant's convictions on direct appeal. Defendant subsequently filed a second petition for postconviction relief, claiming he was entitled to an evidentiary hearing or a new trial based on newly discovered evidence. Defendant also brought a motion for additional fingerprint and forensic DNA testing. The postconviction court summarily denied the petition without an evidentiary hearing. The Supreme Court affirmed, holding (1) Defendant's petition was time-barred as a matter of law, and (2) the motion was not supported by adequate proof.

A jury found Appellant guilty of first-degree premeditated murder, first-degree murder while committing a kidnapping, second-degree intentional murder, and second-degree felony murder in connection with the stabbing death of his girlfriend. The trial court convicted Appellant of first-degree premeditated murder and sentenced him to life in prison without the possibility of parole. The Supreme Court affirmed Appellant's conviction, holding that, given the evidence of Appellant's planning activity, his motive, and the nature of the victim's killing, and given the reasonable inferences to be drawn from that evidence, the evidence of premeditation was sufficient to support Appellant's first-degree premeditated murder conviction.

A jury found Defendant guilty of falsely reporting an act of police misconduct under Minn. Stat. 609.505, subd. 2 (the statute) based on the fact that Defendant informed a police officer that another officer forged her signature, knowing that the information conveyed was false. The court of appeals reversed, concluding that the statute was unconstitutional because it criminalizes false speech critical of the police but not false speech that favors the police. The Supreme Court reversed, holding (1) the court of appeals erred in finding the statute unconstitutional because it criminalizes only defamatory speech not protected by the First Amendment and because it was within two of the exceptions to the constitutional prohibition against content discrimination in an unprotected category of speech; but (2) because Defendant's conviction under the statute preceded the Court's narrow construction of the statute, due process considerations entitled her to a new trial. Remanded.

At issue in this case was whether a statutory amendment to Minn. Stat. 253B.19, 2(d) effective in August 2010, applied to Appellant's November 2008 petition for provisional or full discharge from civil commitment as a sexually dangerous offender. Appellant argued that retroactive application of the amended statute to his petition was improper because the amendment introduced a new, higher burden for a petitioner seeking provisional or full discharge than the version of the statute that was operative when he filed his petition. The court of appeals affirmed the supreme court judicial appeal panel's decision to deny Appellant's petition. The Supreme Court affirmed, holding that the court of appeals properly evaluated Appellant's petition under the amended version of Minn. Stat. 253B.19, 2(d).

A jury found Appellant, Betsy Marie Hanks, guilty of first- and second-degree murder for the shooting death of her romantic partner. In preparation for trial, Hanks sought and received funding from the district court to hire an expert witness on battered woman syndrome. At trial, the district court granted the State's motion to prohibit the expert from testifying. After the guilty verdicts were returned, the district court convicted Hanks on both counts of murder. On appeal, Hanks asserted that the district court erred by excluding the battered woman syndrome expert testimony and by entering convictions on both first- and second-degree murder for a single act. The Supreme Court affirmed in part and reversed in part, holding (1) the district court did not err in excluding the expert testimony, as the evidence of a troubled relationship between Hanks her partner was insufficient to establish the type of relationship that would give rise to battered woman syndrome; and (2) the district court erred in convicting Hanks of both murder offenses. Remanded to the district court to vacate Hanks's conviction for second-degree murder.

The State filed a delinquency petition against Appellant, alleging that Appellant committed second-degree intentional murder. The juvenile court certified the proceeding to adult court. Appellant was charged in district court with second-degree intentional murder. The complaint was amended to include second-degree felony murder. The jury found Appellant guilty of second-degree felony murder and second-degree manslaughter. Appellant appealed, arguing that the district court lacked subject-matter jurisdiction over the amended charge of second-degree felony murder and the lesser-included offense of second-degree manslaughter. The court of appeals affirmed, holding (1) the district court had jurisdiction over the charge specified in the certification order and other charges arising out of the same behavioral incident; and (2) the certification process did not violate Appellant's right to procedural due process. The Supreme Court affirmed, holding (1) a "proceeding" permitted by statute includes non-enumerated offenses arising out of the same behavioral incident as the offense enumerated in the certification order; and (2) following a valid certification order, a child no longer has a liberty interest in a juvenile adjudication for offenses arising out of the behavioral incident certified to adult court, and therefore the district court is not required to conduct another hearing on the certification issue.

Defendant was convicted of one count of felony harassment/stalking following a plea agreement. Defendant sought to apply jail credit to his harassment/stalking conviction sentence even though the jail credit claim was based on time Defendant spent in custody on an unrelated parole violation. When the district court sentenced Defendant, the court implicitly denied Defendant any credit for time spent in custody on the parole violation. The postconviction court held that Defendant was not entitled to any jail credit because the police did not have probable cause to arrest Defendant on the harassment/stalking charge until after he was released from prison on the parole violation. The court of appeals affirmed on different grounds. The Supreme Court also affirmed but on different grounds, holding that Defendant was not entitled to apply to his felony harassment/stalking sentence the jail credit he claimed for time spent in custody on the unrelated parole violation because, while in custody, the State had not completed its investigation into the harassment/stalking offenses, and it was not after Defendant was released from custody that the State had both probable cause and sufficient evidence to charge him with the harassment/stalking offenses with a reasonable likelihood of convicting him of those offenses.

Petitioner was convicted of first-degree murder committed for the benefit of a gang and attempted first-degree murder committed for the benefit of a gang. The Supreme Court affirmed Petitioner's convictions. Petitioner subsequently filed a petition for postconviction relief, claiming several violations of his right to counsel. The postconviction court denied Petitioner's petition without a hearing. The Supreme Court affirmed the decision of the postconviction court, holding that Petitioner was not entitled to postconviction relief on his claims of ineffective assistance of appellate counsel when his petition did not identify any prejudice resulting from the failure of Petitioner's counsel to raise specific challenges o the State's evidence and did not identify any federal constitutional claims that counsel unreasonably failed to raise.