Justia Constitutional Law Opinion Summaries

Articles Posted in Minnesota Supreme Court
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The Supreme Court affirmed the decision of the court of appeals affirming Defendant's convictions for first-degree sexual conduct and domestic assault by strangulation, holding that Minn. R. Crim. P. 9.01 subs. 1-1a does not authorize an inspection of a crime scene in the control of a third party and that, even if Defendant had a constitutional right to inspect the crime scene, any error in denying that right was harmless. Before trial, Defendant filed a motion to allow his counsel and investigator to enter his former residence to inspect and photograph the crime scene. The district court denied the motion. The court of appeals held that Defendant had a right under Rule 9.01, subs. 1-1a, to inspect the crime scene but was not entitled to a new trial because the denial of his motion to inspect was harmless. The Supreme Court affirmed, holding (1) Rule 9.01, subs. 1-1a, does not allow the State to allow a defendant to inspect a crime scene that is the control of a third party; and (2) even if assuming Defendant had the constitutional inspection rights he asserted here, any error in denying his motions to inspect the property was harmless beyond a reasonable doubt. View "State v. Lee" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals upholding the district court's ruling that the admission of statements made by Defendant using a foreign language interpreter did not violate the Confrontation Clause of the Sixth Amendment to the United States Constitution or hearsay rules, holding that the Confrontation Clause was not violated in this case and that the statements were not subject to the hearsay rules. The district court convicted Defendant of first-degree criminal sexual conduct and sentenced him to 144 months in prison. Defendant appealed, arguing that the admission of his translated statements violated the Confrontation Clause and hearsay rules. The court of appeals upheld the district court's ruling that the court's admission of the interpreter's translated statements were proper. The Supreme Court affirmed, holding that the translated statements did not violate the Confrontation Clause and that the district court did not abuse its discretion in admitting the translated statements into evidence over the hearsay objection by Defendant. View "State v. Lopez-Ramos" on Justia Law

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The Supreme Court affirmed in part and reversed in part the judgment of the court of appeals ruling that Minnesota’s vehicle forfeiture statute, Minn. Stat. 169A.63, is unconstitutional as applied to Helen and Megan Olson, holding that the statute is constitutional on its face and constitutional as applied to Megan but unconstitutional as applied to Helen. Megan was arrested for driving while impaired (DWI) and was subject to being charged with a first-degree DWI offense. Because a first-degree DWI offense is a “designated” offense under the DWI vehicle forfeiture statute, the vehicle Megan was driving when she was arrested - a 1999 Lexus owned by Megan’s mother Helen - was subject to forfeiture. The police seized the vehicle incident to Megan’s lawful arrest. The Olsons filed a demand for judicial determination of the forfeiture, arguing that section 169A.63(9)(d), which sets forth the procedural requirements for judicial hearings related to vehicle forfeiture for a DWI offense, violated their due process rights. The district court determined that the statute was unconstitutional on its face. The court of appeals affirmed on different grounds. The Supreme Court held that the statute was constitutional as applied to Megan, who did not own the vehicle, but unconstitutional as applied to Helen, the purportedly innocent owner. View "Olson v. One 1999 Lexus" on Justia Law

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The Supreme Court reversed the decision of the court of appeals reversing the judgment of the district court denying the motion for summary judgment filed by the City of Minneapolis as to Plaintiff’s claims under the Human Rights Act that the City discriminated against him by failing to accommodate his disability and retaliated against him for seeking an accommodation, holding that Plaintiff’s claims under the Human Rights Act were not barred by the exclusive-remedy provision of the Minnesota Workers’ Compensation Act. In moving for summary judgment, the City argued that Plaintiff’s claims were barred by the exclusivity provision in the Workers’ Compensation Act. The district court denied summary judgment. The court of appeals reversed. The Supreme Court overruled its decision in Karst v. F.C. Hayer Co., 447 N.W.2d 180 (Minn. 1989) and reversed, holding that an employee can pursue claims under both the Workers’ Compensation Act and the Human Rights Act because each act provides a distinct cause of action that redresses a discrete type of injury to an employee. View "Daniel v. City of Minneapolis" on Justia Law

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The Supreme Court affirmed the decision of the postconviction court summarily denying Appellant’s present petition for postconviction relief, holding that the record conclusively established that Appellant was not entitled to relief. Appellant was convicted of aiding and abetting first-degree felony murder. After the conviction was affirmed on direct appeal, Appellant filed three petitions for postconviction relief, each of which was summarily denied. At issue int his appeal was Appellant’s fourth petition for postconviction relief, which the postconviction court denied without an evidentiary hearing. The Supreme Court affirmed, holding that Appellant was not entitled to relief on any of his claims. View "Crow v. State" on Justia Law

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The Supreme Court affirmed Defendant’s convictions but reversed his sentence for first-degree murder of an unborn child, holding that the plain language of Minn. Stat. 609.106 does not authorize a sentence of life imprisonment without the possibility of release for a conviction of first-degree murder of an unborn child. Defendant was convicted of first-degree premeditated murder and first-degree premeditated murder of an unborn child. The Supreme Court upheld the convictions but reversed Defendant’s life sentence, holding (1) structural error did not occur when the district court judge presided over Defendant’s jury trial after defense counsel commented during an ex parte conversation that Defendant might commit perjury; (2) Defendant received effective assistance of counsel; (3) the district court did not commit plain error in its jury instructions; and (4) Defendant’s sentence of life imprisonment without the possibility of release for his conviction of first-degree murder of an unborn child was not authorized by section 609.106. View "State v. Mouelle" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals affirming the decision of the postconviction court that Defendant was entitled to a new trial because a juror was actually biased and not sufficiently rehabilitated but that the search of Defendant did not violate his Fourth Amendment rights. Defendant was convicted of possession of a firearm by an ineligible person. Thereafter, Defendant filed a postconviction petition arguing that the district court erred in denying his for-cause strike of Juror 18 and that the police unreasonably searched and seized him, violating his Fourth Amendment rights. The postconviction court rejected Defendant’s Fourth Amendment argument but concluded that the district court committed reversible error by denying the motion to strike Juror 18 for cause. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the search of Defendant was objectively reasonable under the emergency-aid exception to the Fourth Amendment warrant requirement; and (2) Defendant was entitled to a new trial because the presence of the actually biased juror. View "Ries v. State" on Justia Law

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The Supreme Court held that the decision of the United States Supreme Court in Birchfield v. North Dakota, 579 U.S. __ (2016), and this Court’s decisions in State v. Trahan, 886 N.W.2d 216 (Minn. 2016), and State v. Thompson, 886 N.W.2d 224 (Minn. 2016), announced a new rule of constitutional law that applies retroactively to cases on collateral view. In this consolidated appeal arising from two separate traffic stops, the Supreme Court reviewed the decision of the court of appeals concluding that the Birchfield rule did not apply retroactively to Defendant’s final convictions because the rule was procedural in nature, and that, therefore, the district courts properly denied Defendant’s postconviction petitions. The Supreme Court reversed and remanded to the district court for further proceedings, holding that the Birchfield rule is substantive and applies retroactively to Defendant’s convictions on collateral review. View "Johnson v. State" on Justia Law

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The Supreme Court held that Minnesota’s Legend Drug Tax, Minn. Stat. 295.52(4), applies to a non-resident pharmacy’s delivery of prescription drugs to Minnesota-based patients and doctors and that such application does not violate the Due Process Clause or Commerce Clause of the United States Constitution. Respondent-pharmacy requested funds from the Department of Revenue for taxes paid under the Legend Drug Tax on transactions between Respondent’s non-resident pharmacies and Minnesota-based patients and doctors. The Commissioner of Revenue denied the refunds. The Tax Court granted summary judgment for Respondent, concluding that the Legend Drug Tax did not apply to the transactions at issue. The Supreme Court reversed, holding that the tax did apply to the transactions and that application of the tax comported with the Due Process and Commerce Clauses of the United States Constitution. View "Walgreens Specialty Pharmacy, LLC v. Commissioner of Revenue" on Justia Law

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The Supreme Court held that a warrantless narcotics-dog sniff in the hallway outside Defendant’s apartment did not violate Defendant’s right to be free from unreasonable searches under the Minnesota and United States Constitutions. A jury found Defendant guilty of first-degree and fifth-degree possession of a controlled substance and possession of a firearm by a prohibited person. The court of appeals reversed the convictions, concluding that the narcotics-dog sniff in the hallway immediately adjacent to Defendant’s apartment door was a search under the Fourth Amendment because it violated Defendant’s reasonable expectations of privacy and that the warrantless search of Defendant’s home was unreasonable. The Supreme Court reversed, holding (1) the police did not intrude upon the curtilage of Defendant’s apartment or his reasonable expectation of privacy when they conducted the dog sniff, and therefore, no Fourth Amendment search occurred; and (2) because the police were lawfully present in the hallway and had a reasonable suspicion of criminal activity, the dog sniff did not violate Minn. Const. art. I, section 10. View "State v. Edstrom" on Justia Law