Justia Constitutional Law Opinion Summaries

The State charged Defendant under Minn. Stat. 609.352, subd. 2a(2) with felony communication with a child describing sexual conduct after she sent sexually explicit images and messages to a fifteen-year-old boy. Defendant filed a motion to dismiss, arguing that section 609.352, subd. 2a(2) proscribes a substantial amount of speech that the First Amendment protects and thus facially violates the First Amendment. The district court concluded that the statute violates the First Amendment, and the court of appeals affirmed. The Supreme Court reversed, holding that 609.352, subd. 2a(2) is not substantially overbroad in relation to its plainly legitimate sweep. View "State v. Muccio" on Justia Law

After Appellant pleaded guilty to third-degree criminal sexual conduct, removal proceedings were initiated against him. In an attempt to avoid deportation, Appellant filed an emergency motion to withdraw his guilty plea, arguing, inter alia, that he received ineffective assistance of counsel because counsel failed accurately to inform him that his plea would lead to his removal from the United States. Specifically, Appellant argued that Padilla v. Kentucky required his attorney to advise him that the plea would result in his deportation, rather than just the deportation was a possibility. The postconviction court denied Appellant’s motion. The court of appeals affirmed. The Supreme Court affirmed, holding that Padilla did not require Appellant’s counsel to do anything more than provide a general warning about the immigration consequences of entering the plea, and therefore, Appellant’s counsel satisfied his obligation under the Sixth Amendment. View "Sanchez v. State" on Justia Law

Defendant was arrested and charged with drug-related crimes. The district court ordered Defendant’s pretrial release. The district court later found probable cause that Defendant had violated the conditions of her release and issued a warrant for her arrest. Officers then went to the residence of Defendant’s boyfriend. One officer opened an unlocked door, went inside, and arrested Defendant. While arresting her, the officer saw marijuana and a bong in plain view. Law enforcement then obtained a search warrant for the apartment of Defendant’s boyfriend. The state subsequently charged Defendant with two counts of fifth-degree possession of a controlled substance and possession of drug paraphernalia. The district court suppressed all fruits of Defendant’s arrest and dismissed the charges, concluding that the arrest was illegal because the warrant for Defendant's arrest did not authorize police to enter her boyfriend’s apartment. The court of appeals reversed. The Supreme Court affirmed, holding that neither the Fourth Amendment of the U.S. Constitution nor Article I, Section 10 of the Minnesota Constitution requires police to obtain a search warrant before entering a home to arrest a guest who is the subject of a lawfully issued arrest warrant. View "State v. deLottinville" on Justia Law

After declaring his write-in candidacy for President of the United States for the 2016 general election, Steve Carlson filed a request with the Secretary of State asking him to count the votes cast for his candidacy. The Secretary of State refused to accept the request because Carlson did not “include the name of a candidate for vice-president of the United States” with the request pursuant to Minn. Stat. 204B.09, subdivision 3(b). Carlson then filed this petition with the Supreme Court asking the Court to direct the Secretary of State to accept his request because requiring him to name a vice-presidential candidate burdens the First Amendment associational rights of write-in candidates and the voters who support those candidates. The Supreme Court denied the petition, holding that the requirement for write-in candidates to designate a vice-presidential candidate does not violate the associational rights protected by the First Amendment. View "Carlson v. Simon" on Justia Law

Defendant pled guilty to felony domestic assault in district court. Following sentencing, Ramsey County Community Corrections notified the district court that Defendant was required to register as a predatory offender due to his conviction. Defendant filed a motion to withdraw his guilty plea on the ground that he had not been aware that his conviction would trigger the requirement to register as a predatory offender. The district court denied the request. The court of appeals affirmed. The Supreme Court affirmed, holding that a defense attorney’s failure to advise a defendant about predatory offender registration requirements before the defendant enters a plea of guilty does not violate a defendant’s right to effective assistance of counsel, and therefore, Defendant was not entitled to withdraw his guilty plea. View "Taylor v. State" on Justia Law

After a jury trial, Defendant was found guilty of possession of a firearm by an ineligible person for possessing a BB gun. The court of appeals affirmed, concluding that an air-powered BB gun is a “firearm” within the meaning of Minn. Stat. 609.165 and that section 609.165 was not unconstitutionally vague as applied to Defendant. The Supreme Court reversed and vacated Defendant’s conviction, holding that an air-powered BB gun is not a “firearm” under the plain meaning of section 609.165, and therefore, Defendant’s possession of an air-powered BB gun did not violate the statute. View "State v. Haywood" on Justia Law

Appellant was convicted of first-degree murder for the benefit of a gang on an accomplice-liability theory. The Supreme Court affirmed. After unsuccessfully filing two postconviction petitions, Appellant filed a third postconviction petition in which he alleged that three witnesses presented false testimony at his trial. Following an evidentiary hearing, the postconviction court denied Appellant’s third postconviction petition. The Supreme Court affirmed, holding (1) the postconviction court did not err when it rejected Appellant’s claim that the prosecutor intimidated a recanting witness when it apprised the witness of his Fifth Amendment rights; and (2) the postconviction court did not err when it struck the testimony the witness gave before invoking his Fifth Amendment privilege. View "Caldwell v. State" on Justia Law

After a jury trial, Defendant was found guilty of first-degree premeditated murder, second-degree intentional murder, and second-degree felony murder. The district court sentenced Defendant, who was eighteen years old at the time he committed the offense, to life in prison without the possibility of release for the first-degree premeditated murder conviction. The Supreme Court affirmed as modified, holding (1) the district court did not err when it denied Defendant’s motion to suppress his confessions because the confessions were voluntary; (2) Defendant forfeited his claim that his mandatory sentence of life imprisonment without the possibility of release violates the Eighth Amendment prohibition on cruel and unusual punishment because he was psychologically and socially a juvenile when he committed the crime; and (3) because the order attached to the Warrant of Commitment incorrectly listed convictions for the two lesser-included offenses, those two convictions are vacated. View "State v. Nelson" on Justia Law

After Defendant was arrested on suspicion of driving while impaired, officers requested that he submit to a warrantless blood or urine test. Defendant agreed to provide a urine sample, but the officer believed that Defendant tampered with the sample and therefore treated his conduct as a refusal. Defendant refused to submit to a blood test. The State charged Defendant with first-degree refusal. Defendant pleaded guilty. Defendant later argued that his guilty plea was not knowing, voluntary, or intelligent because the test refusal statute was unconstitutional as applied. The postconviction court denied relief. The court of appeals affirmed. After deciding State v. Bernard, the Supreme Court reversed the court of appeals’ decision that the test refusal statute was constitutional and remanded for reconsideration. On remand, the court of appeals reversed Defendant’s conviction. The Supreme Court affirmed, holding that Defendant cannot be prosecuted for refusing to submit to an unconstitutional warrantless blood test, and the test refusal statute is unconstitutional as applied. View "State v. Trahan" on Justia Law

After Defendant was arrested on suspicion of driving while impaired, officers asked him to submit to a warrantless blood or urine test. Defendant refused both tests. The State charged Defendant with second-degree test refusal, among other counts. Defendant moved to dismiss the test refusal charge, arguing that the statute was unconstitutional. The district court denied the motion and found Defendant guilty of test refusal. The court of appeals reversed, concluding that charging a defendant with test refusal violates a fundamental right. The Supreme Court affirmed, holding that the test refusal statute is unconstitutional as applied to Defendant. View "State v. Thompson" on Justia Law