Justia Civil Rights Opinion Summaries

Lincoln Caldwell was convicted in district court of aiding and abetting first-degree premeditated murder for the benefit of a gang. Caldwell appealed his conviction and the denial of two postconviction petitions. The Supreme Court affirmed, holding that (1) Minn. Stat. 609.05 permits the conviction of a defendant for aiding and abetting first-degree murder notwithstanding the fact that the party who fired the shots that killed the victim was acquitted of first-degree murder and convicted of second-degree murder; (2) there was sufficient evidence for the jury to conclude that the party who fired the shots that killed the victim had the necessary intent and premeditation to sustain Caldwell's conviction; and (3) there was sufficient evidence that a group of persons with whom Caldwell associated, and for whose benefit he committed the crime of first-degree murder, was a statutorily-defined gang.

After a jury trial, the district court convicted Ronald Hill of first-degree premeditated murder. The Supreme Court affirmed Hill's conviction, holding (1) because the district court properly and carefully balanced the potential probative value and prejudicial effects of the proffered impeachment evidence, the court did not abuse its discretion when it admitted evidence of Hill's prior, unspecified felony conviction for impeachment purposes; (2) Hill was not entitled to a new trial because allegedly improper testimony that the State obtained Hill's DNA sample through a search warrant was harmless because it did not affect Hill's substantial rights; (3) any alleged error in admitting evidence that Hill shot the victim with a gun stolen during a home invasion was harmless because there was not a reasonable possibility that the alleged error significantly affected the verdict; and (4) the cumulative effect of any errors resulting from the admission of disputed testimony did not affect Hill's substantial rights, and therefore, Hill was not deprived of his constitutional right to a fair trial.

Elizabeth Hawes was convicted of aiding and abetting her brother, Andrew Hawes, in the first-degree murder of their brother, Edwin Hawes. The district court sentenced Hawes to life imprisonment. The Supreme Court affirmed Hawes' conviction, holding (1) the circumstantial evidence was legally sufficient to support Hawes' conviction of aiding and abetting first-degree premeditated murder; (2) any error the the district court made when it ruled that out-of-court statements made by Andrew were not admissible as declarations against penal interest was harmless beyond a reasonable doubt; and (3) the district court did not abuse its discretion when it denied Hawes' motion for a new trial on the grounds of newly available evidence.

Toby Johnson was indicted for intentional murder while committing a kidnapping, murder in the second degree, and kidnapping. Pursuant to a plea agreement, the State amended the first count to aiding and abetting first-degree murder. Johnson then pleaded guilty to counts one and two. Johnson was sentenced to life in prison with a possibility of parole after thirty years. The postconviction court denied Johnson's petition for postconviction relief, and the Supreme Court affirmed. Later, Johnson filed a motion to correct or reduce his sentence, alleging that his guilty plea was invalid for several reasons. The district court concluded that the sentencing court had erred during the sentencing hearing by citing to the second-degree murder statute when imposing a sentence for first-degree murder. As to Johnson's other reasons for requested relief, the court concluded that the Supreme Court's rule from State v. Knaffla barred Johnson from raising claims that were not raised in his first petition for postconviction relief. On appeal, the Supreme Court affirmed the postconviction court's denial of Johnson's motion challenging the validity of his guilty plea, holding that Johnson's petition was untimely and should not be considered on the merits.

This case involved the assault of a pregnant woman, who, after the assault, received a cesarean section. The baby, named Destiny, later died. After a jury trial, Dameon Gatson was convicted of first-degree premeditated murder for aiding the perpetrator in the killing of Destiny and first-degree assault. On appeal, the Supreme Court affirmed, holding (1) the trial court did not err when it upheld the State's strike of a prospective juror; (2) the evidence was sufficient to support the verdict; (3) the trial court did not err by not instructing the jury on whether Destiny was a "human being" for purposes of the homicide statutes and on whether the removal of Destiny's life support was a superseding intervening cause of her death; (4) any error in admitting portions of the perpetrator's guilty plea was harmless beyond a reasonable doubt and any violation of Gatson's right to confrontation was harmless; (5) Gatson was not entitled to relief on his claim that the admission of the perpetrator's guilty plea violated hearsay rules; and (6) the trial court did not abuse its discretion in denying Gatson's motion for a new trial based on newly discovered evidence.

John Miles was convicted of first-degree murder. Miles filed a petition for postconviction relief, alleging that he was entitled to a new trial on the basis of newly discovered evidence, specifically, the information in an interview between Miles's counsel and a witness of the homicide, who stated that Miles was not responsible for the shooting of the victim. The postconviction court denied the petition, concluding that it was time-barred under Minn. Stat. 590.01. On review, the Supreme Court affirmed without prejudice, holding (1) the postconviction court erred when it determined that the witness's statement could have been discovered by the exercise of due diligence prior to trial, (2) the postconviction court applied the wrong legal test when it concluded that the witness's statement did not establish by a clear and convincing standard that Miles was innocent, but (3) the court did not err when it denied Miles's petition without a hearing because Miles failed to offer newly discovered evidence with sufficient indicia of reliability to warrant relief under the statute. The Court concluded if Miles could base a new petition on a more satisfactory showing of a genuine statement from the witness, he was entitled to file a new petition.

Daniel Dalbec was found guilty of third-degree criminal sexual conduct. At Dalbec's trial, counsel for the State and Dalbec agreed to submit written closing arguments to the trial court, but defense counsel failed to submit a closing argument. On appeal, Delbec argued that he was entitled to a new trial based on a structural error that allegedly occurred when the trial court adjudicated his guilt without having received a closing argument from his counsel. The court of appeals reversed Dalbec's conviction and granted Dalbec a new trial based on the structural error. The Supreme Court granted the State's petition for review and reversed the court of appeals. At issue was whether defense counsel's failure to submit a written closing argument constituted structural error requiring automatic reversal and a new trial. The Court held (1) defense counsel's failure to submit a closing argument did not result in structural error, and (2) the trial court's adjudication of Dalbec's guilt without the benefit of closing argument was not structural error. Remanded.

Diane Cox was charged with issuing dishonored checks with a value of more than $500 in violation of the dishonored-check statute, which is a felony. Cox filed a motion to dismiss, arguing that the sentencing disparity between the dishonored-check statute and the theft-by-check statute violated her constitutional right to equal protection of the law because issuing a dishonored check is a lesser-included offense of theft-by-check yet is punished more harshly than the greater offense. The district court denied Cox's motion but certified to the court of appeals the question of whether the disparity in the severity of punishment between the two statutes, which arguably contemplate the same acts committed under the same circumstances by persons in like situations, constitutes an equal protection violation as applied to defendant and those similarly charged. The appellate court answered the question in the negative. The Supreme Court affirmed, holding that Cox is not similarly situated to a defendant who commits theft by check because her conduct would not support a conviction for theft by check, and therefore Cox was not denied equal protection of the law.

In district court, appellant was convicted of aiding and abetting first-degree premeditated murder. At issue was whether the district court erred when it denied appellantâs pretrial motion to suppress statements made to law enforcement officials after appellant allegedly invoked his state and federal constitutional rights to remain silent and to have counsel present during custodial interrogation. The Supreme Court affirmed, holding (1) an invocation of the right to remain silent is ambiguous if the suspectâs statement could be interpreted as either a general refusal to answer any questions or as an expression of unwillingness to discuss a specific topic, and (2) when a suspect makes an equivocal invocation of the right to counsel, providing the suspect with a Miranda warning is sufficient as a matter of law to satisfy Minnesotaâs âstop and clarifyâ rule.