Justia Constitutional Law Opinion Summaries

After a jury trial, Appellant was convicted of first-degree premeditated murder and sentenced to life imprisonment without the possibility of release. Appellant appealed, alleging several claims of error. The Supreme Court affirmed, holding (1) the district court did not deprive Appellant of his Sixth Amendment right to counsel when it denied his request for advisory counsel to assume full representation of his case at trial; (2) the district court did not commit errors that, either individually or taken together, denied Appellant a fair trial; and (3) Appellant was not prejudiced by any error in the district court’s refusal to instruct the jury on the lesser-included offense of first-degree manslaughter. View "State v. Chavez-Nelson" on Justia Law

Appellant was charged with second-degree intentional murder. Appellant offered to plead guilty to that charge, but the State rejected the offer. A grand jury subsequently indicted Appellant for first-degree premeditated murder. Appellant was convicted and sentenced to life imprisonment. Appellant appealed and sought postconviction relief, claiming ineffective assistance of counsel and prosecutorial misconduct. The postconviction court denied relief. The Supreme Court affirmed, holding (1) the district court did not err in denying Appellant’s motion to dismiss the first-degree murder indictment as untimely; (2) the postconviction court did not err in dismissing Appellant’s ineffective assistance claim without an evidentiary hearing; and (3) the postconviction court’s findings that there was no prosecutorial misconduct were not clearly erroneous. View "State v. Vang" on Justia Law

After a jury trial, Appellant was convicted of six counts of soliciting and promoting prostitution and conspiracy to commit sex trafficking. The district court sentenced Appellant to an aggregate sentence of 432 months’ imprisonment. The court of appeals affirmed. The Supreme Court affirmed the convictions, holding (1) the statute that criminalizes the promotion and solicitation of prostitution is not substantially overbroad under the First Amendment; (2) the district court gave plainly erroneous accomplice-liability jury instructions, but the instructions did not affect Appellant’s substantial rights; and (3) the evidence presented at trial was sufficient to support Appellant’s convictions. View "State v. Washington-Davis" on Justia Law

After a jury trial, Defendant was convicted of two counts of first-degree premeditated murder, first-degree arson of a dwelling and theft of a motor vehicle. The Supreme Court affirmed on appeal. Thereafter, Defendant filed a petition for postconviction relief, alleging claims of trial error, ineffective assistance of trial counsel, and ineffective assistance of appellate counsel. The postconviction court denied the petition without granting an evidentiary hearing, concluding that Defendant’s claims were either procedurally barred or meritless. The Supreme Court affirmed, holding (1) Defendant’s claims of trial error were procedurally barred; (2) Defendant’s ineffective assistance of trial counsel claims were either procedurally barred or did not otherwise entitle him to an evidentiary hearing; and (3) Defendant did not receive ineffective assistance of appellate counsel. View "Zornes v. State" on Justia Law

Following a bench trial, a district court found appellant Marcus Barshaw guilty of first-degree premeditated murder in connection with the shooting death of Jeffery Schutz and first-degree assault of a peace officer in connection with an assault committed against Deputy Chad Meemken. The court sentenced Barshaw to life in prison without the possibility of release. On appeal, Barshaw argued that the evidence presented at trial was insufficient to support his convictions of premeditated murder and first-degree assault of a peace officer. Because the evidence was sufficient to support both convictions, the Supreme Court affirmed. View "Minnesota v. Barshaw" on Justia Law

After a jury trial, Defendant was convicted of first-degree premeditated murder on an accomplice-liability theory. The district court sentenced Defendant to life imprisonment without the possibility of release. The Supreme Court affirmed, holding (1) the district court did not err in denying Defendant’s motion to suppress evidence seized as a result of her arrest, as the arrest was supported by probable cause; (2) the district court did not err in overruling Defendant’s challenges to the State’s peremptory strikes of certain jurors under Batson v. Kentucky; (3) the district court did not abuse its discretion when instructing the jury on accomplice liability; and (4) Defendant’s pro se contentions lacked merit. View "State v. Onyelobi" on Justia Law

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, holding (1) the district court did not err when it denied Defendant’s motion to suppress statements from a police interview conducted shortly after the murder; (2) the warrantless seizure of Defendant’s cellphone did not violate her constitutional rights; (3) Defendant was not entitled to relief on her claim that defective search warrants violated her constitutional rights; (4) the district court did not err when it failed to give an accomplice-corroboration jury instruction; (5) the district court did not err in denying Defendant’s request to remove a juror for cause; and (6) the evidence was sufficient to support Defendant’s conviction of first-degree premeditated murder. View "State v. Horst" on Justia Law

Respondent was pulled over by a police office on suspicion of driving while impaired for taking a wide right turn and weaving once within his lane around 2 a.m. Respondent was arrested and subsequently charged with second degree driving while impaired. Respondent moved to dismiss the charges, arguing that the arresting officer lacked a valid basis for the traffic stop. The trial court denied the motion to dismiss. Respondent was subsequently found guilty of one count of second-degree driving while impaired-alcohol concentration of 0.08 or more within two hours. The court of appeals reversed, concluding that the stop was improper. The Supreme Court reversed, holding that, under the totality of the circumstances, the arresting officer had a reasonable, articulable suspicion to justify the vehicle stop. View "State v. Morse" on Justia Law

After a bench trial, Defendant was convicted of third-degree possession of a controlled substance. Defendant appealed, arguing that the district court erred by denying his motion to suppress the heroin seized from the car he was driving on the grounds that the police unlawfully searched the car without a warrant. The court of appeals reversed, concluding that the police did not have probable cause to arrest Defendant or to search his car. The Supreme Court reversed, holding that the warrantless search of Defendant’s car was lawful under the automobile exception because there was probable cause to believe that Defendant’s car contained contraband, and therefore, the district court properly denied Defendant’s motion to suppress. View "State v. Lester" on Justia Law

After a jury trial, Appellant was found guilty of first-degree murder while committing child abuse, second-degree felony murder, and second-degree manslaughter. The district court imposed a life sentence with eligibility for supervised release after thirty years. The Supreme Court affirmed the conviction, holding (1) the jury instruction describing felony malicious punishment of a child as a type of child abuse was plainly erroneous, but Appellant failed to establish that the erroneous jury instruction affected her substantial rights; (2) assuming that the district court abused its discretion when it allowed a state expert to testify that biting a child is a “particularly vicious” form of child abuse, there was no reasonable likelihood that the testimony significantly affected the verdict in this case; and (3) the prosecutor made improper remarks during closing argument, but the prosecutorial misconduct did not affect Appellant’s substantial rights. View "State v. Peltier" on Justia Law