Justia Constitutional Law Opinion Summaries

In this case involving the constitutionality of the Minnesota Unclaimed Property Act the Supreme Court held (1) owners of interest-bearing bank accounts have a constitutionally protected property right that is taken when the State does not compensate the owners for lost interest after transferring and holding unclaimed property under the Act; and (2) the notice provided under the Act to owners of such property valued over $100 is sufficient to satisfy the requirements of due process.Appellants in this case were four property owners whose property was presumed abandoned under the Act and transferred to the State. Appellants alleged that they did not receive sufficient notice that their property had been remitted to the State, in violation of their due process rights, and that the Act effected an unconstitutional taking because they did not receive constructive interest on the unclaimed property after it was delivered to the State. The Supreme Court held that the State was not required to pay interest to some of Appellants in this case because the unclaimed property at issue was not interest bearing and that the notice provided to Appellants under the Act met the requirements of procedural due process. View "Hall v. State" on Justia Law

The Fifth Amendment privilege against self-incrimination does not protect a person from being ordered to prove a fingerprint to unlock a seized cellphone.The police lawfully seized a cellphone from Defendant and attempted to execute a valid warrant to search the cellphone, which had a fingerprint-scanner security lock that prevented the search. When Defendant refused to block the cellphone with his fingerprint the district court ordered Defendant to provide his fingerprint so the police could search the cellphone’s contents. The court of appeals affirmed, concluding that providing a fingerprint was not privileged under the Fifth Amendment. The Supreme Court affirmed, holding that because providing the fingerprint elicited only physical evidence from Defendant and did not reveal the contents of his mind, no violation of the Fifth Amendment privilege against self-incrimination occurred. View "State v. Diamond" on Justia Law

Appellant Emile Rey pleaded guilty to one count of identity theft involving eight or more direct victims. The district court ordered Rey to pay the mandatory-minimum restitution of $1,000 to each of his 66 direct victims, totaling $66,000. Rey appealed, asserting that the mandatory-minimum restitution he was ordered to pay violated his procedural and substantive due process rights and was an unconstitutional fine. The court of appeals affirmed. Rey asked the Minnesota Supreme Court to declare the statute unconstitutional, vacate the restitution order, and remand the matter for a restitution hearing or a Blakely trial. The Court declined, and affirmed the restitution order. View "Minnesota v. Rey" on Justia Law

Under the totality of the circumstances of this case, the police did not violate the Fourth Amendment when, during their execution of a warrant to search a home, they searched a purse that belonged to a guest at the home.Defendant was charged with third-degree controlled-substance crime for possessing methamphetamine. Defendant moved to suppress the methamphetamine found in her pursue, arguing that the search violated the Fourth Amendment because the search of her purse was beyond the scope of the search warrant. The district court denied the motion. The court of appeals affirmed. The Supreme Court affirmed, holding that, taken together, the facts showed that the search of Defendant’s purse was reasonable, and therefore, the search did not violate her Fourth Amendment rights. View "State v. Molnaux" on Justia Law

After the Governor, on May 30, 2017, vetoed line-item appropriations to the Legislature for its biennial budget, the Legislature commenced this action arguing that the line-item veto power cannot be used over the appropriations to itself without violating the Separation of Powers clause. The Governor argued in response that the line-item veto power is expressly conferred on the Executive under Minn. Const. IV, 23. The district court agreed with the Legislature, concluding that the line-item vetoes were unconstitutional under Minn. Const. art. III. The Supreme Court reversed in part and vacated and remanded in part, holding (1) the line-item vetoes did not violate article IV, section 23; (2) the line-item vetoes did not violate Article III by effectively abolishing the Legislature; and (3) this court declined to decide whether those vetoes nonetheless violated Article III as unconstitutionally coercive because the parties failed to resolve their dispute throughout the legislative process contemplated by the Constitution. View "Ninetieth Minnesota State Senate v. Dayton" on Justia Law

The postconviction court did not abuse its discretion in when it denied Appellant’s second petition for postconviction relief without holding an evidentiary hearing.Appellant was found guilty of two counts of first-degree murder and sentenced to consecutive terms of life imprisonment without the possibility of release. The Supreme Court affirmed the convictions on direct appeal. In his first petition for postconviction relief, Appellant raised claims of ineffective assistance of trial and appellate counsel. The Supreme Court affirmed the postconviction court’s summary denial of the first petition. After hiring a private investigator to look into his case, Appellant filed a second postconviction petition. The Supreme Court affirmed the postconviction court’s summary denial of the petition, holding that even if Appellant proved the facts alleged in the petition at an evidentiary hearing, the petition, files, and records of the proceedings conclusively showed that Appellant was not entitled to relief. View "Zornes v. State" on Justia Law

The Supreme Court affirmed the tax court’s denial of relief to Ronald and Dee Johnson, who filed this action challenging the property taxes that Hennepin County assessed against their property. The tax court granted the County’s motion to dismiss the petition for tax years 2007 through 2012 because those claims were not filed in compliance with Minn. Stat. 278.01-.02 and dismissed the Johnson’s constitutional claims for lack of jurisdiction. The tax court then granted judgment in favor of the County on the Johnsons’ remaining claims challenging the assessment for the 2013 tax year. Thereafter, the tax court denied the Johnsons’ five post-trial motions. The Supreme Court affirmed, holding that the evidence in the record adequately supported each of the tax court’s decisions at issue. View "Johnson v. County of Hennepin" on Justia Law

Plaintiff may file a petition for an order declaring her eligible for compensation under Minnesota’s Imprisonment and Exoneration Remedies Act, Minn. Stat. 590.11, 611.362-.368.Several years after the Supreme Court reversed Plaintiff’s conviction for second-degree manslaughter Plaintiff filed a petition seeking remuneration as an “exonerated” individual under section 590.11. The district court denied the petition, concluding (1) Petitioner was not “exonerated” under the statute because the prosecutor never dismissed the second-degree-manslaughter charge, and (2) the prosecutorial-dismissal requirement does not violate equal protection. The court of appeals, however, ruled that the prosecutorial-dismissal requirement violates equal protection and severed the requirement from the remainder of the provision rather than invalidating the entirety of section 590.11(1)(1)(i). The Supreme Court reversed, holding (1) Plaintiff was not “exonerated” under the statute when the Supreme Court reversed her conviction; (2) a statute cannot constitutionally require a prosecutor to dismiss charges that have already been reversed by an appellate court; and (3) the remedy for the as-applied equal-protection violation is to sever section 590.11(1)(1)(i) from the remainder of the statute. View "Back v. State" on Justia Law

The part of Minnesota’s disorderly-conduct statute that prohibits “disturb[ing]” assemblies or meetings, Minn. Stat. 609.72(1)(2), violates the First Amendment.Defendant was convicted of disorderly conduct under section 609.72(1)(2) after a jury trial. On appeal, Defendant argued that the statute violates the First Amendment because it is unconstitutionally overbroad, unconstitutionally vague, and unconstitutional as applied. The court of appeals affirmed, concluding that the constitute was constitutional and was not subject to standard overbreadth analysis. The Supreme Court reversed, holding that the statute suffers from substantial overbreadth and that there is no reasonable narrowing construction of the statute. View "State v. Hensel" on Justia Law

The Supreme Court declined Appellants’ invitation to depart from the United States Supreme Court’s decision in Camara v. Municipal Court, 387 U.S. 523 (1967) and hold that Minnesota’s constitution requires that an administrative search warrant be supported by probable cause of the sort required in a criminal investigation. Camara held that an administrative warrant satisfies the probable cause requirement if reasonable legislative or administrative standards for conducting an unconsented-to rental housing inspection are satisfied with respect to a particular dwelling. In this case, the City of Golden Valley petitioned the district court for an administrative search warrant to search rental property for compliance with the city code. The district court denied the petition for the administrative search warrant, concluding that the issuance of such a search warrant was foreclosed without suspicion of a code violation. The court of appeals reversed. The Supreme Court affirmed, holding that the Minnesota Constitution does not require individualized suspicion of a code violation to support an administrative search warrant for a rental housing inspection. View "City of Golden Valley v. Wiebesick" on Justia Law