Justia Civil Rights Opinion Summaries

Appellant Darryl Colbert was convicted of premeditated first-degree murder. The Supreme Court affirmed Colbert's conviction on direct appeal. Colbert subsequently filed five petitions for postconviction relief, and the postconviction court denied each petition. In this case, Colbert appealed the postconviction court's denial of his fifth petition for postconviction relief. The Supreme Court affirmed, holding that Colbert's petition was time-barred under Minn. Stat. 590.01, subd. 4, which states that a person seeking relief has two years from the disposition of the person's direct appeal to file a petition for postconviction relief, because it was filed more than two years after it arose.

Michael Ferguson was convicted of one count of felony drive-by shooting at an occupied building and eight counts of second-degree assault, arising out of an incident in which multiple shots were fired at a duplex occupied by eight people. After Ferguson successfully appealed his original sentence, the district court imposed sentence on the drive-by shooting conviction and all eight assault convictions. On appeal, the court of appeals held that Minn. Stat. 609.035 required the district court to sentence Ferguson only on the drive-by shooting at an occupied building conviction. The Supreme Court reversed the court of appeals and upheld the sentence imposed by the district court, holding that the court of appeals misapplied the rule that a district court may not sentence a defendant to more than one crime for each victim, and that a single sentence for drive-by shooting at an occupied building was not commensurate with Ferguson's culpability for using a dangerous weapon to intentionally cause eight persons to fear immediately bodily harm.

Appellant Gary Roby was convicted of aiding and abetting the crimes of first-degree premeditated murder, first-degree murder while committing aggravated robbery, and second-degree intentional murder. The Supreme Court affirmed Roby's conviction on appeal. Roby subsequently filed this, his third petition for postconviction relief, arguing that newly discovered evidence should be considered in the interests of justice. The postconviction court denied Roby's petition without an evidentiary hearing, holding (1) Roby's claims that were based on a 1989 police report and a 2002 letter were time-barred, and (2) Roby's remaining claims failed on the merits. The Supreme Court affirmed, holding (1) all of Roby's claims were time-barred under the postconviction statute, and (2) Roby was not entitled to relief through application of the doctrine of equitable tolling.

Appellant Brent Kuhlmann was convicted after a jury trial of domestic assault and test refusal. On appeal, Appellant argued that the trial court committed reversible error when it accepted a stipulation on elements of the charged offenses without advising him of his right to a jury trial on these elements and securing, either in writing or on the record, his personal waiver of the right to a jury trial on the stipulated elements. The court of appeals affirmed Appellant's convictions. The Supreme Court affirmed, holding (1) the trial court erred in failing to obtain Appellant's personal waiver of the right to a jury trial on the previous-conviction elements of the charged offenses; (2) the trial court's failure to obtain Appellant's personal waiver of his right to a jury trial did not amount to structural error; and (3) under the plain error standard, the error did not affect Appellant's substantial rights or the outcome of the case.

Appellant Mahdi Ali was indicted for murder in the first degree and murder in the second degree for the shooting deaths of three individuals. The indictment alleged that Ali was seventeen years old on the date of the alleged offenses and therefore automatically subject to trial in the district court. Ali moved to dismiss the indictment, contending that he was fifteen years old on the date of the shootings and that the jurisdiction of the juvenile court was therefore exclusive. The district court denied the motion, concluding that Ali had reached his sixteenth birthday before the date of the shootings. The court of appeals dismissed Ali's appeal, concluding that the district court's order denying Ali's motion to dismiss the indictment was not appealable. The Supreme Court reversed in part and affirmed in part, holding (1) the denial of a defendant's motion to dismiss an indictment for murder for lack of subject matter jurisdiction is immediately appealable as of right; and (2) when the age of the defendant determines the jurisdiction of the court, the State has the burden of proving, by a preponderance of the evidence, the defendant's age on the date of the alleged offense.

Following a bench trial, Keonne Palmer was found guilty of first-degree premeditated murder, second-degree intentional murder, and possession of a firearm by a prohibited person. Palmer appealed. The Supreme Court affirmed, holding (1) the circumstantial evidence in this case led to the conclusion that Palmer considered, planned, and prepared for the victim's death, and therefore, the evidence was sufficient to support a conviction of premeditated murder; (2) any failure by the district court to consider lesser-included manslaughter offenses could not have affected Palmer's substantial rights because the inclusion of manslaughter charges would not have affected the outcome; and (3) the trial court did not improperly pronounce Palmer's sentence.

After a jury trial, Brett Borg was found guilty of third-degree criminal sexual conduct. During the trial, the district court allowed a police officer to testify in the State's case in chief that Borg did not respond to a request for an interview by the officer. The court of appeals reversed Borg's conviction, concluding that the district court erred when it allowed the officer to testify about "silence in response to police questions or attempts to pose questions." The Supreme Court reversed the court of appeals and affirmed Borg's conviction, holding that the Fifth Amendment does not prohibit the State from introducing evidence during the State's case in chief regarding a defendant's silence unless the government compelled the defendant to speak or remain silent.

William Jacobs was charged with two counts of criminal sexual conduct. Jacobs moved to remove the judge assigned to his case for cause, basing his motion on the fact that the judge had not disclosed that his spouse was, at the time, an attorney with the county attorney's office that was prosecuting the case. Jacobs' motion was denied. The court of appeals denied Jacobs' writ of prohibition, holding that a spouse's position as an assistant county attorney in the public office that is prosecuting the case does not by itself create an appearance of partiality. The Supreme Court affirmed, holding that the judge was not required to disqualify himself from the case because a reasonable examiner, with full knowledge of the facts and circumstances in this case, would not question the judge's impartiality.

Following a jury trial, Lawrence Montanaro was convicted of first-degree murder of a police officer. After the statute of limitations for filing a postconviction petition expired, Montanaro filed a petition for postconviction relief. The postconviction court denied the petition without deciding whether Montanaro established an exception to the statute of limitations. The Supreme Court affirmed, holding that the postconviction court did not abuse its discretion in denying Montanaro's request for a new trial based on the court's conclusion that alleged errors in the jury instructions and the prosecutor's alleged misconduct during his closing argument did not satisfy the third prong of the plain error test because the errors did not affect Montanaro's substantial rights.

Appellant Victor Martinez-Mendoza was charged by complaint with one count of first-degree criminal sexual conduct and one count of second-degree criminal sexual conduct. The State and Appellant reached a plea agreement in which Appellant would plead guilty to count two of the complaint and count one would be dismissed. Appellant subsequently pleaded guilty to count two, and the district court adjudged Appellant guilty of count two. Before the sentencing hearing, the State learned that the actual presumptive guidelines sentence for the count two offense involved a much shorter incarceration time than the parties had originally thought. The State moved to vacate the plea or, in the alternative, reinstate count one of the complaint. The district court denied the motion, citing double jeopardy concerns. The court of appeals reversed based on the parties' mutual mistake. The Supreme Court reversed, holding that jeopardy attached when the trial court accepted and recorded Appellant's guilty plea, and thus, any appeal by the State was barred as moot as a matter of law.