Justia Civil Rights Opinion Summaries

The Supreme Court affirmed Defendant's conviction of first-degree premeditated murder, holding that the State presented sufficient evidence to support the conviction and that the sentence imposed upon Defendant was not unconstitutionally cruel.After a jury trial, Defendant was convicted of first-degree premeditated murder and sentenced to life imprisonment without the possibility of release. The Supreme Court affirmed the conviction and sentence, holding (1) there was sufficient evidence in the record to support the conviction; and (2) a mandatory sentence of life without the possibility of release is not unconstitutionally cruel under Minn. Const. art. I, section 5 when imposed on a twenty-one-year-old defendant who has been convicted of first-degree premeditated murder. View "State v. Hassan" on Justia Law

The Supreme Court affirmed Defendant's conviction of first-degree felony murder and his sentence of life imprisonment as well as the denial of his petition for postconviction relief, holding that sufficient evidence supported the conviction and that Defendant's constitutional and ineffective assistance of counsel challenges failed.After he was convicted Defendant filed a direct appeal. The Supreme Court stayed the appeal to allow Defendant to pursue postconviction relief. The district court denied the petition following an evidentiary hearing. The Supreme Court lifted the stay, consolidated Defendant's appeal, and affirmed, holding (1) the evidence was sufficient to support the conviction; (2) Defendant's arguments related to a witness's identification testimony failed; (3) Defendant's right to a speedy trial was not violated; and (4) Defendant's claims of ineffective assistance of counsel were without merit. View "State v. Jones" on Justia Law

The Supreme Court affirmed the judgment of the district court imposing a mandatory five-year conditional release term in connection with Defendant's conviction of fourth-degree assault of a secure treatment facility employee of the Minnesota Sex Offender Treatment Program (MSOP), holding that there was a rational basis for the sentencing disparity at issue in this case.After he was convicted, Defendant filed a petition for postconviction relief arguing that Minn. Stat. 609.2231, subd. 3a(e) required the district court to impose different sentences for the same conduct based on the defendant's civil commitment status, and therefore, his sentence violated his equal protection rights under the United States and Minnesota Constitutions. The district court denied postconviction relief, and the court of appeals affirmed. The Supreme Court affirmed, holding that the disparate sentence survived rational basis review. View "State v. Lee" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's convictions on two counts of first-degree burglary and two counts of second-degree assault, holding that there was no error.After the jury announced its verdicts in this case Defendant exercised his right to poll the jury. While the record showed that the jury was composed of twelve members, the transcript of the jury polling contained only eleven responses. On appeal, Defendant argued that the evidence was insufficient to prove that he was afforded his constitutional right to a unanimous, twelve-person jury. The court of appeals affirmed. The Supreme Court affirmed, holding (1) sufficient evidentiary support in the record established that Defendant was found guilty by a twelve-member jury; and (2) Defendant was not entitled to relief for any error in the jury polling because it was not a structural error, and Defendant did not satisfy the plain error doctrine. View "State v. Bey" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming the judgment of the district court finding Defendant guilty of four counts of violence under Minn. Stat. 609.713, subd. 1, holding that section 609.713, subd. 1 does not violate the First Amendment.After he was charged, Defendant filed a motion to dismiss, claiming that the portion of section 609.713, subd. 1 that applies to threats of violence made "in a reckless disregard of the risk of causing such terror" was unconstitutionally overbroad. The district court denied the motion and found Defendant guilty. The court of appeals affirmed, concluding that even if the statute prohibited some protected speech, it was not facially overbroad under the First Amendment. The Supreme Court affirmed, holding (1) specific intent is not required to make a communication a true threat; (2) the statute punishes only reckless speech that is a true threat; and (3) because few situations of reckless but protected threats would be swept up in criminal prosecutions, the statute is not facially overbroad. View "State v. Mrozinski" on Justia Law

The Supreme Court affirmed the decision of the district court summarily denying as time-barred Defendant's second petition for postconviction relief, holding that even if the facts alleged in the petition were proven at an evidentiary hearing, Defendant still would not be entitled to relief.Defendant was convicted of first-degree premeditated murder. The Supreme Court affirmed both Defendant's conviction on direct appeal and the denial of his first postconviction motion. In his second postconviction petition, Defendant argued the the district court lacked subject matter jurisdiction, that he had discovered new evidence, prosecutorial misconduct, and ineffective assistance of counsel. The district court denied the petition. The Supreme Court affirmed, holding that Defendant's claims either failed on the merits or were time barred. View "Martin v. State" on Justia Law

The Supreme Court reversed Defendant's conviction of illegal possession of ammunition, holding that the district court erred by denying Defendant's motion to suppress.During a traffic stop, law enforcement officers questioned Defendant, who was a passenger in the stopped vehicle, regarding the conditions of his pretrial release. After Defendant was arrested for violating a condition of his pretrial release, a pat-down search revealed ammunition in Defendant's pocket. Defendant filed a motion to suppress, arguing that the officer’s questions about the conditions of his pretrial release improperly expanded the scope of the traffic stop. The district court denied the motion, and the court of appeals affirmed. The Supreme Court reversed, holding (1) violation of a condition of pretrial release does not constitute criminal activity allowing a law enforcement officer to expand the scope of a traffic stop; and (2) the officer's questioning of Defendant about the conditions of his pretrial release exceeded the permissible scope of a traffic stop. View "State v. Sargent" on Justia Law

The Supreme Court affirmed the decision of the court of appeals holding that a law enforcement officer lawfully expanded the scope of the underlying traffic stop in this case, holding the court of appeals did not err.Defendant was convicted of first-degree driving while impaired and possessing an opened bottle or receptacle containing an alcoholic beverage. On appeal, Defendant argued that the district court erred by denying his motion to suppress evidence because the officer impermissibly expanded the scope of the underlying traffic stop by asking Defendant if he had consumed any beer from the open case in his vehicle. The court of appeals affirmed. The Supreme Court affirmed, holding that the circumstances known to the officer and the legitimate inferences to be drawn from them raised a reasonable articulable suspicion of other criminal activity sufficient to expand the scope of the traffic stop. View "State v. Taylor" on Justia Law

The Supreme Court affirmed the judgment of the district court summarily denying Appellant's claims for postconviction relief, holding that the district court did not abuse its discretion.After a jury trial, Defendant was convicted of first-degree premeditated murder as a principal and as an aider and abettor and sentenced to life in prison without the possibility of release. Defendant later moved for postconviction relief, alleging that the State committed Brady violations during his criminal trial and other grounds for relief. The district court denied Defendant's petition for postconviction relief without holding an evidentiary hearing. The Supreme Court affirmed, holding that Defendant was not entitled to relief on his claims for postconviction relief. View "Thoresen v. State" on Justia Law

The Supreme Court affirmed the judgment of the trial court convicting Defendant of first-degree criminal sexual conduct, holding that the modified plain error doctrine was not satisfied in this case.On appeal, Defendant argued that a statement made by the prosecutor during his jury trial required reversal of his conviction and a new trial. At issue was the prosecutor's statement to the jury during closing argument that a unanimous verdict on one element of the offense - specifically, whether Defendant acted with force or with coercion to accomplish the act of sexual penetration - was not required. The court of appeals affirmed, holding (1) the phrase "force or coercion in Minn. Stat. 609.342(a)(e)(i) sets forth alternative means for completing the sexual penetration element of the offense; and (2) therefore, a unanimous jury verdict on whether Defendant used force or coercion was not necessary. The Supreme Court affirmed, holding that no relief was warranted in this case. View "State v. Epps" on Justia Law