Justia Civil Rights Opinion Summaries

Appellant was charged with three counts of fourth-degree controlled substance crime and one count of possession of a firearm by an ineligible person. A public defender was appointed to represent him. Prior to trial, the chief public defender made a motion seeking a discharge of the public defender and an order that Defendant had forfeited his right to counsel by manipulating the court and making threatening statements to his lawyer. After an evidentiary hearing at which Defendant was present but not represented by counsel, the court granted the motion, holding that Defendant had forfeited his right to counsel due to his severe misconduct. Defendant subsequently appeared pro se at his jury trial. The jury found him guilty of all counts. The court of appeals affirmed. The Supreme Court reversed in part, holding that the district court denied Defendant his procedural due process rights. The Court remanded the case to the district court for an evidentiary hearing, at which Defendant would be entitled to due process protections, to determine whether Defendant engaged in "extremely serious misconduct" warranting forfeiture of his right to counsel.

Defendant was convicted, after a stipulated facts bench trial, of first-degree possession of a controlled substance. More than five years after his conviction became final, Defendant filed a petition for postconviction relief. The postconviction court denied Defendant's petition as untimely and meritless. The court of appeals affirmed. The Supreme Court affirmed, holding (1) Appellant's petition was untimely under Minn. Stat. 590.01, 4(c), which requires that a claim is brought within two years from the time the claimant knew or should have known that the claim existed; and (2) section 590.01, subdivision 4 was not unconstitutional as a violation of the separation of powers doctrine where the legislature did not intrude unto a judicial function when it enacted the time limitations provisions in the postconviction statute.

Appellant Alexander Miller pleaded guilty to intentional second-degree murder of Crystal Lindorff by an Alford plea on March 11, 2005. Appellant's conviction was not reviewed on direct appeal. On May 11, 2009, Appellant filed this petition for postconviction relief. The postconviction court denied Appellant's petition, concluding that it was untimely and meritless. The court of appeals affirmed. The Supreme Court affirmed, holding that the postconviction court properly dismissed Appellant's postconviction petition, as (1) because Appellant filed the petition over two years after his claim arose, the petition was untimely; and (2) the time limits were constitutionally applied to Appellant's petition.

Appellant was convicted of first-degree premeditated murder and first-degree murder while committing criminal sexual conduct. Appellant filed a notice of direct appeal, which the Supreme Court stayed pending postconviction proceedings in the district court. Appellant neither filed a petition for postconviction relief nor followed through with his direct appeal, and the Court dismissed his appeal. In this case, Appellant appealed the denial of his first petition for postconviction relief. The Supreme Court affirmed, holding (1) the postconviction court properly denied Appellant's petition as untimely under Minn. Stat. 590.01, 4(a); and (2) the time limit in section 590.01, 4(a) was constitutional as applied to Appellant, because even if the Due Process Clause of the Minnesota Constitution provided Appellant a right to one review, the two-year time limitation in subdivision 4(a) was a reasonable limitation on the alleged right.

Respondent Christian Ndikum was charged with possession of a pistol in public after he carried a briefcase containing a gun into a courthouse. At trial, Respondent requested that the district court instruct the jury that knowledge of possession is an element of the crime of possession of a pistol in public that the State must prove. The district court refused to so instruct the jury, and the jury found Respondent guilty as charged. The court of appeals reversed, concluding that the State had to prove knowledge of possession of a pistol as an element of the crime of possession of a pistol. The Supreme Court affirmed, holding (1) the State was required to prove that Respondent knew he possessed the pistol at issue; and (2) the district court abused its discretion by failing to so instruct the jury.

After a grand jury indicted Defendant on two counts of first-degree premeditated murder, two counts of first-degree felony murder, and two counts of second-degree murder, the district court convicted Defendant on both counts of first-degree premeditated murder. Defendant challenged his convictions on four grounds. The Supreme Court affirmed, holding (1) the district court did not err in denying Defendant's motion for dismissal of the indictment; (2) the record contained sufficient evidence to support the district court's verdict that Defendant was guilty of first-degree premeditated murder rather than heat-of-passion manslaughter; (3) the prosecutor's alleged misconduct during witness questioning did not affect Defendant's substantial rights under the plain-error test; and (4) the allegedly erroneous admission of a witness's out-of-court statement did not substantially influence the district court's verdict, and therefore, Defendant was not entitled to a new trial.

Jerrell Brown was convicted of aiding and abetting first-degree murder for the benefit of a gang in connection with a shooting death. On appeal, Brown (1) challenged his conviction, claiming that the trial court violated his right to a public trial and erred in its evidentiary rulings and jury instructions, and (2) claimed the prosecutor violated his right to a fair trial by failing to disclose impeachment evidence. The Supreme Court affirmed Brown's conviction, holding (1) because the facts of this case did not implicate the right to a public trial, the trial court did not err in its evidentiary rulings or its jury instructions; and (2) the undisclosed impeachment evidence was not material.

When Appellant Amanda Tatro was a junior in the mortuary science program at the University of Minnesota, she posted statements on Facebook which she described as "satirical commentary and violent fantasy about her school experience." Following a hearing, the Campus Committee on Student Behavior (CCSB) found Tatro had violated the student conduct code and academic program rules governing the privilege of access to human cadavers, which prohibited "blogging" about cadaver dissection. CCSB imposed sanctions, including a failing grade for an anatomy laboratory course. The University Provost affirmed the sanctions. Tatro appealed, arguing that the University violated her constitutional rights to free speech. The court of appeals upheld the disciplinary sanctions. The Supreme Court affirmed, holding that the University did not violate the free speech rights of Tatro by imposing sanctions for her Facebook posts that violated academic program rules where the academic program rules were narrowly tailored and directly related to established professional conduct standards.

In a motion to withdraw his guilty plea, Respondent Reyes Campos argued the the U.S. Supreme Court's decision in Padilla v. Kentucky, which held that the Sixth Amendment right to counsel included the right to be informed about the deportation consequences of a guilty plea, applied retroactively to his conviction. Based on Padilla, Campos conended that his attorney's failure to warn him of the deportation consequences of his guilty plea constituted ineffective assistance of counsel and rendered his plea invalid. The district court determined that Padilla could not be applied to Campos' collateral attack on his conviction. The court of appeals reversed. The Supreme Court reversed, holding that Padilla announced a new rule of criminal procedure that does not apply to a collateral review of Campos' conviction. Remanded.

The State charged Brandon Smith with gross misdemeanor possession of a pistol without a permit and misdemeanor illegal transportation of a firearm. The charges resulted from Smith's possession of a pistol retrieved from his car by two state troopers during an otherwise lawful traffic stop. The district court convicted Smith of both charged offenses and sentenced him. The court of appeals vacated the misdemeanor sentence for illegal transportation of a firearm but affirmed the gross misdemeanor sentence of possession of a pistol without a permit. At issue on appeal was whether the district court erred by denying Smith's motion to exclude the pistol from evidence. The Supreme Court affirmed, holding that the troopers did not unlawfully expand the scope of the traffic stop without reasonable, articulable suspicion of illegal activity, and therefore, the district court did not err when it admitted the pistol into evidence.