Justia Civil Rights Opinion Summaries

Following a jury trial, Appellant Danny Ortega was convicted of aiding and abetting first-degree premeditated murder. The Supreme Court affirmed Ortega's conviction, holding (1) the district court did not err in denying Ortega's motion to suppress his statements to investigators because, after requesting counsel, Ortega reinitiated the discussion with investigators and then validly waived his right to counsel; (2) the district court did not abuse its discretion when it allowed the prosecutor to ask prospective jurors whether they believed there was anything more valuable than human life, as any error in the prosecutor's questioning of jurors during voir dire was harmless; and (3) the evidence was sufficient to convict Ortega of premeditated murder.

Appellant Jabaris Curt Boldman was found guilty by a jury of first-degree felony murder and second-degree intentional murder. The district court entered judgment of conviction for first-degree felony murder and imposed a life sentence. The Supreme Court vacated Appellant's conviction for first-degree felony murder, holding (1) the evidence was not sufficient to support the first-degree felony murder conviction but was sufficient to support a second-degree murder conviction; and (2) any alleged discovery violation on the part of the State was harmless. Remanded to the district court to enter a judgment of conviction and impose sentence on the second-degree murder charge.

Peter Lonergan and Robert Kunshier were both indeterminately civilly committed to the Minnesota sex offender program. Lonergan and Kunshier each sought relief from his commitment by filing a pro se motion under Minn. R. Civ. P. 60.02. After the district court denied the motions, both Lonergan and Kunshier appealed. The court of appeals affirmed the denial of Lonergan's motion, holding that as a sexually dangerous person, Lonergan could not use Rule 60.02 to seek a discharge from his indeterminate commitment or to make a constitutional challenge to the adequacy of his treatment at the sex offender program. The court also affirmed the denial of Kunshier's motion, concluding that Rule 60.02 may not be used to seek any relief from an indeterminate civil commitment order. The Supreme Court reversed in part, holding (1) the court of appeals erred in Kunshier's case when it articulated a blanket prohibition on use of Rule 60.02 motions by patients indeterminately committed as sexually dangerous persons or sexual psychopathic personalities; and (2) Lonergan's claims warranted reconsideration in light of this decision. Remanded.

The Rochester International Joint Zoning Board enacted a zoning ordinance that increased the size of a runway safety zone and changed the restrictions within the safety zone to allow fewer types of uses of land within the zone. The safety zone extended over property owned by Leon and Judith DeCook. The DeCooks brought an inverse condemnation action, alleging that the Board's decision constituted a taking for which the DeCooks were entitled to compensation. The district court first concluded there was no taking, and upon remand, again concluded that the Board's actions did not constitute a taking. The DeCooks appealed another time, and the Supreme Court ultimately held the ordinance constituted a taking of the DeCooks' property. The DeCooks subsequently moved for an award of attorney fees incurred during the appeals. The Supreme Court granted the motion, as the Cooks prevailed and were entitled under Minn. Stat. 117.045 to an award of reasonable costs and expenses, including attorney fees, incurred on appeal.

After a jury trial, Appellant Daniel Anderson was convicted of first-degree murder for the death of his girlfriend's nineteen-month-old son. Anderson filed a petition for postconviction relief, arguing that it was error for the State to indict him under the domestic abuse murder statute and that he should have been indicted under what he claimed to be the more specific child abuse murder statute. The postconviction court denied relief without a hearing, reasoning that the claim was Knaffla-barred and that no exception to Knaffla applied. Under State v. Knaffla, a postconviction relief petition raising claims that were raised on direct appeal or that were known or should have been known but were not raised by the petition at the time of direct appeal is procedurally barred. The Supreme Court affirmed, holding that the postconviction court properly concluded that Anderson's claim was Knaffla-barred and that Anderson's petition was not saved by either exception to the Knaffla bar, as his claim was not novel and the interests of fairness and justice did not warrant consideration of his claim.

Appellant was convicted on six controlled substance crimes. The court of appeals affirmed Brist's convictions but remanded for the district court to modify Brist's sentence. On appeal, Brist argued that the admission of an audio recording of a statement made by her nontestifying coconspirator to a confidential government informant during a drug transaction violated her rights under the Confrontation Clause. The Supreme Court affirmed Brist's convictions, concluding that it was bound by Bourjaily v. U.S., which held that recorded statements of a nontestifying coconspirator, otherwise admissible as nonhearsay under materially identical evidentiary rules, are admissible at trial against another coconspirator without violating the Confrontation Clause. Therefore, the district court's admission into evidence of the coconspirator's statements in this case did not violate Brist's rights under the Confrontation Clause.

The State charged Ronald Fleck with second-degree assault after he stabbed his former girlfriend. During the trial, after all the evidence was presented to the jury, the district court submitted two forms of assault to the jurors, (1) assault-fear, prohibiting an act done with the intent to cause fear in another of immediate bodily harm or death, and (2) assault-harm, prohibiting the intentional infliction of bodily harm. The district court instructed the jurors that voluntary intoxication applied to an assault-fear offense but not an assault-harm offense. The jury found Fleck not guilty of second-degree assault-fear but guilty of second-degree assault-harm. The court of appeals reversed, concluding that the district court erred by failing to instruct the jury that voluntary intoxication applied to an assault-harm offense. The Supreme Court reversed the court of appeals' decision and reinstated Fleck's conviction, holding that the district court properly instructed the jury on the applicable law.

Appellant Herman Tanksley, Jr. was convicted of fourth-degree driving while impaired, which is driving with an alcohol concentration of 0.08 or more. Tanksley appealed, arguing that he was entitled to a Frye-Mack hearing on the reliability of first-void urine testing to resolve his claim that first-void urine testing does not reliably correlate with a driver's blood alcohol concentration. The court of appeals concluded that the district court abused its discretion in denying the Frye-Mack hearing to Tanksley but that the error was harmless. The Supreme Court granted transfer and affirmed the district court, holding that the district court was not required to hold a Frye-Mack hearing based on Tanksley's challenge, as blood alcohol concentration is irrelevant when the State seeks to prove the offense of driving with an alcohol concentration of 0.08 or more solely with evidence of the amount of alcohol in the defendant's urine.

Defendant Randolph Johnson was charged with felony domestic assault and misdemeanor fifth-degree assault. As part of a negotiated plea, Defendant pleaded guilty to an amended charge of misdemeanor domestic assault, and the State dismissed the felony charge. The district court ordered that Defendant submit to a DNA sample pursuant to Minn. stat. 609.117, subd. 1(1), which requires a defendant charged with a felony and then convicted of a misdemeanor arising out of the same set of circumstances to submit a DNA sample for the limited purpose of criminal identification, after concluding that the statute was constitutional as applied to Defendant. The Supreme Court affirmed after applying a totality-of-the-circumstances test, holding (1) the State's legitimate governmental interests in conducting a search of Defendant to collect a biological specimen for criminal identification purposes outweighed Defendants' reduced expectation of privacy following his misdemeanor conviction arising out of the same set of circumstances as his felony charge; (2) consequently, the statute did not violate the prohibitions against unreasonable searches and seizures in the state and federal constitutions; and (3) Defendant's equal protection claim failed.

Appellant, a juvenile, was petitioned for a felony and then adjudicated delinquent of a misdemeanor arising out of the same set of circumstances. The court ordered that Appellant provide a biological speciman to determine her DNA profile for the limited purpose of criminal identification after concluding that Minn. Stat. 609.117, subd. 1(2), which requires a juvenile adjudicated delinquent of a misdemeanor to submit a DNA sample, did not violate constitutional prohibitions against unreasonable searches and seizures and was not a denial of equal protection. The Supreme Court affirmed after applying a totality-of-the-circumstances test, holding (1) the State's legitimate governmental interests in collecting Appellant's DNA outweighed Appellant's reduced expectation of privacy following her misdemeanor adjudication arising out of the same set of circumstances as her felony petition; (2) consequently, as applied to Appellant, section 609.177, sub. 1(2) did not violate the prohibitions against unreasonable searches and seizures in the state and federal constitutions; and (3) Appellant's equal protection claim failed because Appellant was not similarly situated to misdemeanants without a felony petition, who were not required to provide a DNA sample under the statute.