Justia Constitutional Law Opinion Summaries

Articles Posted in Minnesota Supreme Court
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The Supreme Court reversed the decision of the court of appeals affirming Defendant's conviction of check forgery, holding that a government inspection of a guest registry is a search under the Minnesota Constitution and that the district court committed reversible error by admitting evidence illegally seized from Defendant's hotel room. Based on evidence that law enforcement officers discovered in Defendant's hotel room, Defendant was charged with check forgery. Defendant filed a motion to suppress, arguing that the officers violated Minn. Const. art. I, 10 when they inspected the hotel guest registry, which led them to his room, without having any individualized suspicion of criminalized activity. The district court denied the motion, and the court of appeals affirmed. The Supreme Court reversed, holding (1) law enforcement officers must have at least a reasonable, articulable suspicion to search a guest registry; (2) the hotel guest registry statutes, Minn. Stat. 327.10-.13 are constitutional because they do not authorize suspicionless searches; and (3) because the evidence admitted in this case was the fruit of the illegal, suspicionless search of the guest registry the district court erred by denying Defendant's motion to suppress. View "State v. Leonard" on Justia Law

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The Supreme Court affirmed Defendant's convictions for first-degree murder and second-degree murder but reversed the sentence in part, holding that the district court erred by entering a formal adjudication on both first-degree murder and second-degree murder but any other error in the proceedings below was harmless. Specifically, the Supreme Court held (1) any error the district court may have made by declining to hold an evidentiary hearing regarding the admissibility of DNA evidence was harmless, and the district court did not abuse its discretion by denying Defendant's motion to exclude the DNA evidence; (2) Defendant was not prejudiced by alleged prosecutorial misconduct; and (3) the district court erred by entering a formal adjudication on both first-degree murder and second-degree murder in its sentencing order, and therefore, the cause must be remanded to the district court to correct the error. View "State v. Garland" on Justia Law

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The Supreme Court affirmed Defendant's conviction for first-degree murder, holding that there was no error in the proceedings below. Specifically, the Supreme Court held (1) Appellant's right to a fair trial before an impartial tribunal was not violated when the district court stated that it might reconsider its prior Spreigl ruling if the defense presented certain witnesses; (2) the jury instructions on accomplice liability were plainly erroneous, but Appellant failed to establish that there was a reasonable likelihood that the error had a significant effect on the verdict; (3) the prosecutor did not commit misconduct in his closing arguments regarding the law of accomplice liability; (4) the district court did not abuse its discretion by granting the State’s motion to admit evidence of appellant’s past convictions for impeachment purposes, including by allowing the specific convictions to be disclosed to the jury; and (5) Appellant’s pro se arguments were without merit. View "State v. Reek" on Justia Law

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The Supreme Court affirmed the decisions of the district court denying Appellant's ineffective assistance of trial counsel claim raised in his first petition for post conviction relief and the claims raised in his second petition for postconviction relief, holding that the district court did not abuse its discretion by denying Appellant's claims. After a jury trial, Appellant was found guilty of first-degree felony murder, attempted first-degree felony murder, and second-degree assault. The Supreme Court affirmed. In his first petition for postconviction relief, Appellant raised some of the same issues addressed in his direct appeal but also claimed that he received ineffective assistance of trial counsel. The district court ordered an evidentiary hearing only on the ineffective assistance of counsel claim and, after a hearing, denied the claim. Appellant then filed a second petition for postconviction relief, which the district court summarily denied. The Supreme Court affirmed both of the district court's orders, holding (1) Appellant did not satisfy the first prong of Strickland on his ineffective assistance of counsel claim; and (2) all of Appellant's claims in his second petition were time barred. View "Griffin v. State" on Justia Law

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The Supreme Court denied Petitioners' petition filed under Minn. Stat. 204B.44(a) asking that the Supreme Court direct the Minnesota Secretary of State to include Roque De La Fuente's name as a candidate for The Republican Party of Minnesota's nomination for United States President on the ballot for the Minnesota presidential nomination primary election on March 3, 2020, holding that Petitioners' claims failed. Petitioners argued that the procedure established by Minn. Stat. 207A.13, which allows a major political party to determine which candidates' names will be on the ballot for a statewide presidential nomination primary, was unconstitutional. The Supreme Court disagreed, holding that section 207A.13 does not violate (1) the prohibition against special privileges because the Legislature had a rational basis for classifying political parties based on a party's participation in a national convention to nominate the party's presidential candidate; (2) the Presidential Eligibility Clause because requiring a political party to identify the candidates for the ballot to be used in a presidential nomination primary is not a condition of eligibility to serve as President of the United States; and (3) Petitioners' rights of free association because any burden imposed on those rights by the ballot preparation procedures is outweighed by the associational rights of political parties and the State's regulatory interests. View "De La Fuente v. Simon" on Justia Law

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In this challenge to a zoning ordinance prohibiting industrial mineral operations within Winona County the Supreme Court affirmed the decision of the court of appeals affirming the order of the district granting summary judgment to the County on all of Minnesota Sands, LLC's claims, holding that the ordinance was constitutional. Minnesota Sands, a mining company, sought to mine and process silica sand in the County. Minnesota Sands sued the County requesting declaratory, injunctive, and monetary relief. The district court granted summary judgment to the County. The court of appeals affirmed, concluding that the ordinance did not violate the dormant Commerce Clause or work an unconstitutional taking of Minnesota Sands' property interests. The Supreme Court affirmed, holding (1) Minnesota Sands had standing to bring this case; (2) the County's ordinance did not violate the dormant Commerce Clause on its face, in purpose or in effect; and (3) Minnesota Sands' takings claims failed because the property interests it claimed were taken by the County had not yet accrued. View "Minnesota Sands, LLC v. County of Winona, Minnesota" on Justia Law

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The Supreme Court affirmed in part and reversed in part the decision of the court of appeals holding that a proposed charter amendment was not manifestly unconstitutional but was an improper referendum, holding that the proposed amendment was not an improper exercise of the charter amendment power and was not manifestly unconstitutional. After the City of Bloomington changed from a system of open trash collection to a system of organized collection a group of residents attempted, through an amendment to the City Charter, to require that voters pre-approve a change in the method of trash collection. The City refused to put the proposed charter amendment on the ballot. In the original appeal, the Supreme Court remanded the case to the court of appeals for decision on whether the proposed amendment would violate the Contract Clauses of the United States and Minnesota Constitutions and whether it was an attempt to exercise the voter referendum power through an improper means. On remand, the court of appeals concluded that the proposed amendment was an improper referendum but was not unconstitutional. The Supreme Court reversed in part, holding that the proposed charter amendment was not an improper referendum and did not violate the Contract Clauses. View "Jennissen v. City of Bloomington" on Justia Law

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The Supreme Court affirmed the judgment of the district court summarily denying Appellant's petition for postconviction relief, holding that the alleged facts, even when viewed in a light most favorable to Appellant, conclusively showed that he was entitled to no relief. Appellant was convicted of murder and attempted murder. Appellant later filed his postconviction petition alleging that several reversible errors were committed by the judge, prosecutor, and his counsel during his jury trial. The district court denied the petition without holding an evidentiary hearing and without addressing the ineffective assistance of appellate counsel claim. The Supreme Court affirmed, holding (1) Appellant's claims were procedurally barred by State v. Knaffla, 243 N.W.2d 737 (Minn. 1976); and (2) the failure to address the ineffective assistance of appellate counsel claim did not require a remand because the facts alleged conclusively showed that Appellant was not entitled to relief on his claim. View "Zumberge v. State" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction for first-degree driving while impaired, holding that Officer Patrick Bendel of the Red Lake Police Department was acting within his proper authority when he detained Defendant and transported him to Beltrami County law enforcement. On appeal, Defendant challenged the denial of his motion to suppress, arguing that all evidence obtained as a result of his arrest should be suppressed because Officer Bendel was not a "peace officer" as defined in Minn. Stat. 169A.03, subd. 18 and therefore could not legally arrest Defendant for driving while impaired. The Supreme Court affirmed, holding (1) Officer Bendel detained and investigated Defendant and ejected him from the Red Lake Reservation pursuant to the tribal authority to detain and remove recognized by federal courts; and (2) therefore, Defendant's detention was lawful. View "State v. Thompson" on Justia Law

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The Supreme Court affirmed the judgment of the district court summarily denying Defendant's petition for postconviction relief, holding that the claims raised in the petition were procedurally barred and that the district court's failure to address Defendant's claim of ineffective assistance of appellate counsel did not require a remand. Defendant was convicted of murder and attempted murder. Defendant later filed a petition for postconviction relief alleging that counsel, the judge, and the prosecutor committed reversible errors during trial. In a supporting memorandum, Defendant alleged an additional claim of ineffective assistance of appellate counsel. The district court denied the petition without a hearing and failed to address the ineffective assistance of counsel claim. The Supreme Court affirmed, holding (1) Defendant's claims were barred by State v. Knaffla, 243 N.W.2d 737 (Minn. 1976); and (2) the facts conclusively showed that Defendant was entitled to no relief on his claims of ineffective assistance of counsel. View "Zumberge v. State" on Justia Law