Articles Posted in Minnesota Supreme Court

by
The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the district court suppressing the results of Defendant's blood test, holding that the limited right to counsel established in Friedman v. Commissioner of Public Safety, 473 N.W.2d 828 (Minn. 1991), does not apply when an individual is asked to submit to a blood test pursuant to a warrant. After Defendant was arrested for driving while impaired, the police officer obtained a search warrant to take a sample of her blood for alcohol concentration testing. The officer read Defendant the implied-consent advisory for blood and urine tests, and Defendant allowed her blood to be drawn. Defendant moved to have the results of her blood test suppressed, arguing that, under Friedman, she had a limited constitutional right to consult with counsel before deciding whether to submit to a blood test. The district court agreed. The Supreme Court disagreed, holding that the limited right to counsel under the Minnesota Constitution recognized in Friedman does not apply when a driver is presented with the choice to submit to a blood test pursuant to a search warrant. View "State v. Rosenbush" on Justia Law

by
The Supreme Court affirmed the judgment of the postconviction court summarily denying Defendant's petition for postconviction relief arguing that counsel provided ineffective assistance and that an expert witness for the State provided unreliable testimony at trial, holding that the postconviction court did not err. Defendant was convicted of first-degree murder and sentenced to life imprisonment. The Supreme Court affirmed Defendant's conviction on direct appeal. Defendant later filed a petition for postconviction relief, which the postconviction court summarily denied. The Supreme Court affirmed, holding that Defendant's claims were either meritless or time-barred. View "Odell v. State" on Justia Law

by
The Supreme Court affirmed Defendant's convictions of first-degree felony murder, attempted first-degree felony murder, drive-by shooting (the underlying felony), and other offenses, holding that the evidence was sufficient to support the drive-by shooting conviction and that the prosecutor did not engage in prosecutorial misconduct. On appeal, Defendant argued, among other things, that the evidence was insufficient to prove that he discharged a firearm "at or toward" a building or vehicle and that the prosecutor committed prosecutorial misconduct when she argued in rebuttal that Defendant's closing argument was trying to play on the jury's emotions. The Supreme Court affirmed, holding (1) there was sufficient evidence for a reasonable jury to find that Defendant discharged a firearm "toward" a building; (2) the prosecutor did not commit misconduct; and (3) Defendant's remaining pro se arguments were without merit. View "State v. Waiters" on Justia Law

by
The Supreme Court reversed the decision of the court of appeals concluding that two Minnesota statutes - Minn. Stat. 609.749, subd. 2(6), the stalking-by-mail provision, and Minn. Stat. 609.795, subd. 1(3), the mail-harassment statute - are constitutional under the First Amendment, holding that both statutes are facially overbroad. A.J.B. was found guilty of gross-misdemeanor stalking by use of the mail, misdemeanor harassment by use of the mail, and felony stalking. The court of appeals affirmed A.J.B.'s adjudications for stalking by mail and mail harassment, thus rejecting his constitutional challenges. On appeal, A.J.B. argued that his adjudications under the stalking-by-mail provision and mail-harassment statute must be vacated as contravening the First Amendment. The Supreme Court held (1) section 609.749, subd. 2(6), is facially overbroad and not subject to either a narrowing construction or severance of unconstitutional provisions; (2) section 609.795, subd. 1(3), is facially overbroad, but the statute can be saved through severance of the constitutionally problematic language; and (3) because it is unclear whether Defendant's adjudication of delinquency for mail-harassment is based on the severed language, Defendant's adjudication under section 609.795, subd. 1(3), is reversed and the case remanded. View "In re A.J.B." on Justia Law

by
The Supreme Court affirmed the decision of the court of appeals affirming Defendant's convictions for first-degree sexual conduct and domestic assault by strangulation, holding that Minn. R. Crim. P. 9.01 subs. 1-1a does not authorize an inspection of a crime scene in the control of a third party and that, even if Defendant had a constitutional right to inspect the crime scene, any error in denying that right was harmless. Before trial, Defendant filed a motion to allow his counsel and investigator to enter his former residence to inspect and photograph the crime scene. The district court denied the motion. The court of appeals held that Defendant had a right under Rule 9.01, subs. 1-1a, to inspect the crime scene but was not entitled to a new trial because the denial of his motion to inspect was harmless. The Supreme Court affirmed, holding (1) Rule 9.01, subs. 1-1a, does not allow the State to allow a defendant to inspect a crime scene that is the control of a third party; and (2) even if assuming Defendant had the constitutional inspection rights he asserted here, any error in denying his motions to inspect the property was harmless beyond a reasonable doubt. View "State v. Lee" on Justia Law

by
The Supreme Court affirmed the decision of the court of appeals upholding the district court's ruling that the admission of statements made by Defendant using a foreign language interpreter did not violate the Confrontation Clause of the Sixth Amendment to the United States Constitution or hearsay rules, holding that the Confrontation Clause was not violated in this case and that the statements were not subject to the hearsay rules. The district court convicted Defendant of first-degree criminal sexual conduct and sentenced him to 144 months in prison. Defendant appealed, arguing that the admission of his translated statements violated the Confrontation Clause and hearsay rules. The court of appeals upheld the district court's ruling that the court's admission of the interpreter's translated statements were proper. The Supreme Court affirmed, holding that the translated statements did not violate the Confrontation Clause and that the district court did not abuse its discretion in admitting the translated statements into evidence over the hearsay objection by Defendant. View "State v. Lopez-Ramos" on Justia Law

by
The Supreme Court affirmed in part and reversed in part the judgment of the court of appeals ruling that Minnesota’s vehicle forfeiture statute, Minn. Stat. 169A.63, is unconstitutional as applied to Helen and Megan Olson, holding that the statute is constitutional on its face and constitutional as applied to Megan but unconstitutional as applied to Helen. Megan was arrested for driving while impaired (DWI) and was subject to being charged with a first-degree DWI offense. Because a first-degree DWI offense is a “designated” offense under the DWI vehicle forfeiture statute, the vehicle Megan was driving when she was arrested - a 1999 Lexus owned by Megan’s mother Helen - was subject to forfeiture. The police seized the vehicle incident to Megan’s lawful arrest. The Olsons filed a demand for judicial determination of the forfeiture, arguing that section 169A.63(9)(d), which sets forth the procedural requirements for judicial hearings related to vehicle forfeiture for a DWI offense, violated their due process rights. The district court determined that the statute was unconstitutional on its face. The court of appeals affirmed on different grounds. The Supreme Court held that the statute was constitutional as applied to Megan, who did not own the vehicle, but unconstitutional as applied to Helen, the purportedly innocent owner. View "Olson v. One 1999 Lexus" on Justia Law

by
The Supreme Court reversed the decision of the court of appeals reversing the judgment of the district court denying the motion for summary judgment filed by the City of Minneapolis as to Plaintiff’s claims under the Human Rights Act that the City discriminated against him by failing to accommodate his disability and retaliated against him for seeking an accommodation, holding that Plaintiff’s claims under the Human Rights Act were not barred by the exclusive-remedy provision of the Minnesota Workers’ Compensation Act. In moving for summary judgment, the City argued that Plaintiff’s claims were barred by the exclusivity provision in the Workers’ Compensation Act. The district court denied summary judgment. The court of appeals reversed. The Supreme Court overruled its decision in Karst v. F.C. Hayer Co., 447 N.W.2d 180 (Minn. 1989) and reversed, holding that an employee can pursue claims under both the Workers’ Compensation Act and the Human Rights Act because each act provides a distinct cause of action that redresses a discrete type of injury to an employee. View "Daniel v. City of Minneapolis" on Justia Law

by
The Supreme Court affirmed the decision of the postconviction court summarily denying Appellant’s present petition for postconviction relief, holding that the record conclusively established that Appellant was not entitled to relief. Appellant was convicted of aiding and abetting first-degree felony murder. After the conviction was affirmed on direct appeal, Appellant filed three petitions for postconviction relief, each of which was summarily denied. At issue int his appeal was Appellant’s fourth petition for postconviction relief, which the postconviction court denied without an evidentiary hearing. The Supreme Court affirmed, holding that Appellant was not entitled to relief on any of his claims. View "Crow v. State" on Justia Law

by
The Supreme Court affirmed Defendant’s convictions but reversed his sentence for first-degree murder of an unborn child, holding that the plain language of Minn. Stat. 609.106 does not authorize a sentence of life imprisonment without the possibility of release for a conviction of first-degree murder of an unborn child. Defendant was convicted of first-degree premeditated murder and first-degree premeditated murder of an unborn child. The Supreme Court upheld the convictions but reversed Defendant’s life sentence, holding (1) structural error did not occur when the district court judge presided over Defendant’s jury trial after defense counsel commented during an ex parte conversation that Defendant might commit perjury; (2) Defendant received effective assistance of counsel; (3) the district court did not commit plain error in its jury instructions; and (4) Defendant’s sentence of life imprisonment without the possibility of release for his conviction of first-degree murder of an unborn child was not authorized by section 609.106. View "State v. Mouelle" on Justia Law