Justia Constitutional Law Opinion Summaries

Appellant entered into a mortgage with Aegis Lending Corporation. The mortgage was later assigned to Pacifica L. Ninteen, and the servicing rights were eventually transferred to Vantium Capital, Inc. (“Acqura”). After foreclosure proceedings were commenced against Appellant, Appellant filed suit against Acqura, alleging numerous state law claims. Specifically, Appellant claimed that Acqura’s violated its Servicer Participation Agreement with Fannie Mae by failing to follow guidelines applicable under the federal Home Affordable Modification Program. The district court dismissed the lawsuit, holding that Minn. Stat. 58.18(1) did not provide a private cause of action for Appellant to pursue damages for Acqura’s alleged violation of its agreement with Fannie Mae and that Appellant therefore lacked standing. The court of appeals affirmed. The Supreme Court reversed, holding that section 58.18(1) provides for a private right of action and therefore gave Appellant standing to pursue her claim. View "Gretsch v. Vantium Capital, Inc." on Justia Law

Defendant was convicted of two counts of aiding suicide in violation of Minn. Stat. 609.215(1), which makes it illegal to intentionally “advise, encourage, or assist another in taking the other’s own life.” Defendant had responded to posts on suicide websites by encouraging the victims to hang themselves, falsely claiming that he would also commit suicide. Defendant appealed, arguing that section 609.215(1) violated the First Amendment. The court of appeals affirmed, holding that the statute prohibited speech that was unprotected by the First Amendment. The Supreme Court reversed, holding (1) the State may prosecute Defendant for assisting another in committing suicide but not for encouraging or advising another to commit suicide, and thus the words “advises” and “encourages” must be severed from the statute as unconstitutional; and (2) because the district court did not make a specific finding on whether Defendant assisted the victims’ suicides, the case must be remanded. View "State v. Melchert-Dinkel" on Justia Law

Law enforcement officers stopped a truck driven by Thomas Anthony, a suspected drug dealer. Charles Lemert was a passenger in Anthony’s car. Officers ordered Lemert to get out of the truck and proceeded to conduct a pat search of Lemert. Based on the evidence discovered during the pat search, the State charged Lemert with a fifth-degree controlled-substance offense. Lemert moved to suppress the evidence, arguing that the search was unlawful because the officers lacked a reasonable, articulable suspicion that Lemert might have been armed and dangerous. The district court denied the motion and convicted Lemert of the charge. The court of appeals affirmed. The Supreme Court affirmed, holding that, under the circumstances, the officers had a reasonable, articulable suspicion that Lemert might have been armed and dangerous, and therefore, the district court did not err when it denied Lemert’s motion to suppress. View "State v. Lemert" on Justia Law

After Scott Schuette, who was working as a police officer at the time, responded to an accident at the local high school he began experiencing mental health problems. Schuette was later diagnosed with post-traumatic stress disorder (PTSD). Schuette filed a claim petition seeking workers’ compensation benefits for PTSD. A compensation judge denied Schuette’s claim, finding that Schuette’s PTSD lacked a physical component and was thus not a compensable injury under Minnesota law. The Workers’ Compensation Court of Appeals (WCCA) affirmed, determining (1) to be compensable under Lockwood v. Independent School District No. 877, an injury must include a physical component; and (2) the compensation judge’s findings that Schuette’s PTSD did not result in a physical brain injury had substantial evidentiary support. The Supreme Court affirmed, holding (1) the compensation judge’s findings were not manifestly contrary to the evidence; and (2) applying the doctrine of stare decisis, Schuette’s request to overrule Lockwood was declined. View "Schuette v. City of Hutchinson" on Justia Law

Defendant was convicted of murder in the first degree while committing domestic abuse and with a past pattern of domestic abuse. Defendant subsequently filed a petition for postconviction relief, arguing, among other things, that there was insufficient evidence to establish a past pattern of domestic abuse beyond a reasonable doubt. After an evidentiary hearing, the postconviction court denied the petition. The Supreme Court affirmed, holding (1) sufficient evidence supported the jury’s finding that Defendant engaged in a past pattern of domestic abuse against the victim; (2) the district court did not err in its jury instructions on a past pattern of domestic abuse; and (3) the district court did not commit plain error by admitting evidence connected to orders for protection obtained by the victim, as Appellant’s substantial rights were not affected by the admission of this evidence. View "Gulbertson v. State" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder and sentenced to life in prison. Defendant subsequently filed two petitions for postconviction relief, both of which were denied. The instant appeal concerned the postconviction court’s summary denial of Defendant’s second petition for postconviction relief. On appeal, Defendant raised three claims: ineffective assistance of appellate counsel, prosecutorial misconduct, and ineffective assistance of trial counsel. The Supreme Court affirmed, holding that the postconviction court did not err by summarily denying Defendant’s second petition for postconviction relief because all three of Defendant’s claims failed as a matter of law. View "Erickson v. State" on Justia Law

Law enforcement officers obtained a warrant to search Appellant and Appellant’s residence after Appellant allegedly threatened a woman for stealing his drugs. At the apartment the officers seized gun and drug evidence. Appellant filed a motion to suppress, which the district court granted on the ground that the search warrant affidavit failed to establish a sufficient nexus between Defendant’s alleged criminal activity and the apartment. The court of appeals reversed. The Supreme Court affirmed, holding that, based on the totality of the circumstances, the search warrant affidavit established a sufficient nexus between Appellant’s alleged criminal activity and the place to be searched. View "State v. Yarbrough" on Justia Law

After a jury trial, Appellant was convicted of first-degree felony murder while committing a drive-by shooting for the benefit of a gang. The Supreme Court stayed Appellant’s direct appeal to permit Appellant to file a petition for postconviction relief. The postconviction court subsequently denied relief. The Supreme Court consolidated Appellant’s direct and postconviction appeals into a single proceeding and held (1) the record contained sufficient evidence to support Appellant’s conviction; (2) some of the individual jury instructions in this case were erroneous, but the jury instructions, considered as a whole, did not constitute reversible error; (3) Appellant knowingly and voluntarily waived his right to testify at trial; (4) Appellant was not deprived of his right to the effective assistance of trial counsel; (5) the district court did not abuse its discretion when it denied Appellant’s motion for a mistrial; (6) the jury did not return legally inconsistent verdicts; and (7) the postconviction court did not err when it denied an evidentiary hearing on Appellant’s claim that the district court violated his right to a public trial. View "State v. Bahtuoh" on Justia Law

Defendant was convicted of first-degree murder and sentenced to life imprisonment. The Supreme Court affirmed the conviction on direct appeal. Defendant subsequently filed several petitions for postconviction relief. Defendant's fourth petition for postconviction relief alleged that new evidence, an unsworn statement by an alleged eyewitness to the murder, entitled him to a new trial. After an evidentiary hearing, the postconviction court denied Defendant's fourth petition for postconviction relief. The Supreme Court affirmed, holding that the postconviction court (1) did not err in denying Defendant a new trial based on new evidence; (2) did not abuse its discretion in how it handled evidence that Defendant submitted after the evidentiary hearing; and (3) did not err in refusing to grant relief in the interests of justice. View "Miles v. State" on Justia Law

After a jury trial, Defendant was convicted of two counts of felony violation of a domestic abuse no-contact order. The court of appeals reversed and remanded for a new trial, holding (1) the failure to instruct on an element of the charged offense as a matter of law affects a defendant's substantial rights, and (2) Defendant's substantial rights were affected as a matter of law by the district court's failure to instruct the jury on the "knowingly" element of the charged offense. The Supreme Court affirmed but on different grounds, holding (1) an unobjected-to jury instruction that omits an element of the charged offense does not, as a matter of law, affect a defendant's substantial rights, but rather, the trial court must consider certain factors to determine whether the omission of an element of a charged offense from the instruction to the jury was sufficiently prejudicial to warrant a new trial; and (2) the trial court's failure to instruct on the "knowingly" element of the charged offense was an error that affected Defendant's substantial rights. View "State v. Watkins" on Justia Law