Justia Constitutional Law Opinion Summaries

Appellant was charged with first-degree premeditated murder. On the date of the murder, Appellant was seventeen years old. The district court sentenced Appellant to life imprisonment without the possibility of release (LWOR). Appellant later filed a petition for postconviction relief claiming that he was entitled to a new trial because an eyewitness recanted his trial testimony and that his mandatory sentence of LWOR should be reversed based on Miller v. Alabama. The postconviction court denied Appellant’s petition after an evidentiary hearing. The Supreme Court (1) affirmed in part, holding that the postconviction court did not abuse its discretion by ruling that the eyewitness’s out-of-court statements were not admissible under Minn. R. Evid. 804(b)(3); but (2) vacated Appellant’s LWOR sentence because the mandatory statutory scheme under which his sentence was imposed was unconstitutional as applied according to Montgomery v. Louisiana. Remanded for resentencing. View "Jackson v. State" on Justia Law

Appellant filed an action under 42 U.S.C. 1983 against Scott County and Credit River Township, claiming that the County took his property without just compensation by placing conditions on the approval of his plat application. The County moved for summary judgment, arguing that the district court did not have subject-matter jurisdiction because Appellant’s exclusive avenue for review of the County’s decision was to seek a writ of certiorari from the court of appeals. The district court determined that it had jurisdiction over the action. The court of appeals reversed, concluding that the County’s plat approval subject to conditions was a quasi-judicial action, which was reviewable only by certiorari appeal within sixty days. The Supreme Court reversed, holding that the district court had jurisdiction over Appellant’s section 1983 action. View "Zweber v. Credit River Township" on Justia Law

In 2008, Appellant was convicted of three counts of first-degree murder and four counts of second-degree murder. Appellant was sentenced to life imprisonment without the possibility of release. The Supreme Court affirmed on appeal. In 2012, Appellant filed a petition for postconviction relief, alleging numerous trial errors as well as ineffective assistance of counsel. The postconviction court summarily denied most of Appellant’s claims on the ground that they were procedurally barred. Following an evidentiary hearing, the court denied Appellant’s remaining ineffective assistance of counsel claims. The Supreme Court affirmed, holding (1) most of Defendant’s claims were procedurally barred, and therefore, the postconviction court did not abuse its discretion by denying them without granting an evidentiary hearing; and (2) the district court did not err when it denied several of Appellant’s ineffective assistance of counsel claims after an evidentiary hearing. View "Swaney v. State" on Justia Law

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