Justia Constitutional Law Opinion Summaries

Articles Posted in Minnesota Supreme Court
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The Supreme Court affirmed the judgment of the district court denying Defendant's petition for postconviction relief asserting a claim of ineffective assistance of appellate counsel, holding that Defendant's claim failed on the merits. In his petition for postconviction relief Defendant argued that his conviction for first-degree premeditated murder must be set aside based on ineffective assistance of appellate counsel. The district court summarily dismissed Defendant's postconviction petition. The Supreme Court affirmed, holding that the district court did not abuse its discretion in concluding that Defendant was entitled to no relief on his postconviction claim of ineffective assistance of appellate counsel. View "Petersen v. State" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals affirming the district court's denial of Defendant's motion to suppress, holding that the officer formed a reasonable, articulable suspicion to make the traffic stop that led to Defendant's arrest. The officer informed Defendant that he had been stopped because the car's windshield was cracked and because it did not appear that Defendant had been wearing his seat belt. Defendant was subsequently charged with driving while impaired and violating his driver's license restriction. Defendant moved to suppress the evidence obtained as a result of the stop, alleging that the stop was unconstitutional. The district court denied the motion to suppress. The court of appeals affirmed, holding that the officer was not justified in stopping Defendant for the crack in his windshield but that the evidence supported a conclusion that the officer had reasonable suspicion that Defendant was not wearing his seat belt. The Supreme Court affirmed, holding that, even if the officer's observation that Defendant was not wearing his seat belt was mistaken, the mistake was objectively reasonable under the circumstances. View "State v. Poehler" on Justia Law

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The Supreme Court affirmed Defendant's conviction of first-degree felony murder, first-degree aggravated robbery, and possession of a firearm by an ineligible person related to a fatal shooting, holding that the district court did not clearly err by overruling Defendant's Batson objection to the State's peremptory challenge of a prospective juror. On appeal, Defendant argued that the district court erred in overruling his Batson objection to the State's peremptory challenge of the juror because the State's challenge was racially motivated and the proffered explanation for exercising the challenge was pretextual. The Supreme Court affirmed, holding that the district court did not clearly err in determining that the race-neutral reason for striking the juror was not a pretext for racial discrimination. View "State v. Adams" on Justia Law

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The Supreme Court reversed the decision of the court of appeals reversing the district court's decision denying Defendant's petition for postconviction relief asserting the invalidity of a test-refusal conviction under Birchfield v. North Dakota, 579 U.S. ___ (2016), and Johnson v. State, 916 N.W.2d 674 (Minn. 2018), holding that the district court properly placed the burden of proof on Defendant instead of the State. Birchfield announced the rule that, in the absence of a warrant or an exception to the warrant requirement, refusal to submit to a blood or urine test cannot be criminalized. Johnson made the rule retroactive. The district court denied Defendant's request for postconviction relief, concluding that he failed to prove there was no applicable exception to the warrant requirement. The court of appeals reversed, holding that the district court erred by placing the burden of proof on Defendant instead of the State. The Supreme Court reversed and announced a heightened pleading standard for Birchfield/Johnson postconviction proceedings, holding that the district court properly placed the burden of proof on Defendant. View "Fagin v. State" on Justia Law

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The Supreme Court affirmed the judgment of the court of appeals affirming the decision of the Commissioner of the Department of Human Services (DHS) determining that Appellant was permanently disqualified from working in a capacity where he may have contact with people who access services from a DHS-licensed program, holding that Appellant's claims on appeal failed. After DHS discovered a 2002 child-protection report that Appellant had sexually abused his son sometime around 1998, Appellant was disqualified from employment as a residence manager at a DHS-licensed substance abuse treatment program. The court of appeals affirmed DHS's decision. The Supreme Court affirmed, holding (1) Defendant's right to due process was not violated; (2) the Department of Human Services Background Studies Act, Minn. Stat. ch. 245C, does not create a permanent, irrebuttable presumption that DHS's decision was correct; and (3) Appellant was provided constitutionally sufficient notice of his rights under the Act. View "Jackson v. Commissioner of Human Services" on Justia Law

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The Supreme Court affirmed Defendant's convictions for first-degree murder and attempted first-degree murder, holding that Defendant's allegations of error did not warrant reversal of his convictions. Specifically, the Court held (1) the admission of certain evidence did not violate the Fourth Amendment to the United States Constitution or the substantive requirements of Minn. Stat. 626A.42; (2) to the extent the challenged evidence violated Minn. R. Evid. 702 the error was harmless; (3) the district court did not clearly err when it determined that Defendant failed to make a prima facie showing of discrimination under step one of the Batson v. Kentucky, 476 U.S. 79 (1986), inquiry; and (4) Defendant's claims of ineffective assistance of counsel and prosecutorial misconduct were without merit. View "State v. Harvey" on Justia Law

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The Supreme Court reversed the decision of the court of appeals affirming Defendant's conviction, holding that a body cavity search performed by forcing Defendant to be strapped down and sedated in order to undergo an invasive anoscopy against his will in the presence of nonmedical personnel was unreasonable under the Fourth Amendment. After Defendant was strapped down and sedated he was forced against his will to undergo an anoscopy. During the procedure, the doctor located a plastic baggie containing cocaine in Defendant's body cavity. The State charged Defendant with one count of fifth-degree possession of a controlled substance. Defendant moved to suppress evidence of the drugs, arguing that the search, even though conducted pursuant to a valid search warrant, was unreasonable. The district court denied the motion, and Defendant was convicted. The court of appeals affirmed, concluding that the anoscopy was a reasonable search. The Supreme Court reversed, holding that the extreme intrusion of Defendant's dignitary rights by the coerced anoscopy outweighed the State's need to retrieve relevant evidence of drug possession, and therefore, the evidence retrieved from the search must be suppressed. View "State v. Brown" on Justia Law

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The Supreme Court affirmed the judgment of the district court denying Defendant's petition for postconviction relief, holding that the district court did not err in denying the petition without holding an evidentiary hearing. Defendant was convicted of first-degree murder as an accomplice. The Supreme Court affirmed on direct appeal. Thereafter, Defendant filed the present petition for postconviction relief, alleging several claims of error. The district court denied the petition without a hearing, reasoning that Defendant's arguments were either procedurally barred or lacked merit. The Supreme Court affirmed, holding that Defendant's claims were either procedurally barred or failed on the merits. View "Onyelobi v. State" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the district court suppressing the results of Defendant's blood test, holding that the limited right to counsel established in Friedman v. Commissioner of Public Safety, 473 N.W.2d 828 (Minn. 1991), does not apply when an individual is asked to submit to a blood test pursuant to a warrant. After Defendant was arrested for driving while impaired, the police officer obtained a search warrant to take a sample of her blood for alcohol concentration testing. The officer read Defendant the implied-consent advisory for blood and urine tests, and Defendant allowed her blood to be drawn. Defendant moved to have the results of her blood test suppressed, arguing that, under Friedman, she had a limited constitutional right to consult with counsel before deciding whether to submit to a blood test. The district court agreed. The Supreme Court disagreed, holding that the limited right to counsel under the Minnesota Constitution recognized in Friedman does not apply when a driver is presented with the choice to submit to a blood test pursuant to a search warrant. View "State v. Rosenbush" on Justia Law

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The Supreme Court affirmed the judgment of the postconviction court summarily denying Defendant's petition for postconviction relief arguing that counsel provided ineffective assistance and that an expert witness for the State provided unreliable testimony at trial, holding that the postconviction court did not err. Defendant was convicted of first-degree murder and sentenced to life imprisonment. The Supreme Court affirmed Defendant's conviction on direct appeal. Defendant later filed a petition for postconviction relief, which the postconviction court summarily denied. The Supreme Court affirmed, holding that Defendant's claims were either meritless or time-barred. View "Odell v. State" on Justia Law