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 reversing the decision of the district court granting Defendant's motion to suppress his statements to his probation officer and a polygraph administrator about his criminal conduct, holding that suppression of the statements was not required.Specifically, the Supreme Court held (1) Defendant made the statements at issue without invoking his constitutional privilege against self-incrimination, and the penalty exception to the general rule that a person cannot assert the privilege against self-incrimination without first invoking the privilege did not apply; (2) the portion of Minn. Stat. 634.03 requiring exclusion of confessions "made under the influence of fear produced by threats" excludes confessions made under circumstances where the inducement to speak was such that there was a fair risk that the confession was false; and (3) exclusion of Defendant's statements was not required in this case. View "State v. McCoy" on Justia Law

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The Supreme Court affirmed the judgment of the Tax Court upholding that constitutionality of the Minnesota sales or use tax for aircraft purchases, holding that Minn. Const. art. X, 5 bars only the application of duplicative personal property taxes to aircraft.Article X, section 5 allows the Legislature to tax aircraft using the airspace over Minnesota "in lieu of all other taxes." Relators purchased aircraft outside of the state, paid the use tax, paid a separate annual tax imposed on aircraft, and then requested a refund of the use tax. When the refunds were denied, Relators sued the Department of Revenue, arguing that the use tax is unconstitutional under Minn. Const. art. X, 5. The Tax Court granted summary judgment for the Commissioner of Revenue. The Supreme Court affirmed, holding (1) the phrase "[a]ny such tax on aircraft shall be in lieu of all other taxes," as used in article X, section 5, prohibits only the application of duplicative personal property taxes on aircraft; and (2) the tax imposed on aircraft by Minn. Stat. 297A.82 does not violate article X, section 5. View "Sheridan v. Commissioner of Revenue" on Justia Law

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The Supreme Court affirmed the judgment of the district court overruling Appellant's objection to the State's peremptory strike of a prospective juror, holding that Appellant did not meet his burden of proving that the State's race-neutral reason for the strike was a pretext for racial discrimination.Appellant was convicted of first- and second-degree criminal sexual conduct. On appeal, Defendant challenged the State's peremptory strike of the only nonwhite person from the jury venire. The court of appeals affirmed, holding that the prosecutor's explanations for striking the venire-person were race-neutral reasons for the peremptory strike. The Supreme Court affirmed, holding that the district court did not err in denying Appellant's Batson challenge to the State's peremptory strike of the juror. View "State v. Lufkins" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals affirmed the orders of the district court dismissing Appellant's constitutional claims asserting discrimination in the tax assessments of its properties, holding that Appellants' claims were time-barred.Appellant, Walmart, Inc., owned real property in two counties (the Counties). In this action, Walmart claimed that for tax purposes the Counties overvalued the properties or unfairly assessed the properties' value as compared with other similarly situated properties. Appellant asserted that the Counties' international discrimination in their tax assessments violated the Equal Protection Clause and Appellant's right to uniformity in taxation. The district court dismissed the claims as time-barred, and the court of appeals affirmed. The Supreme Court affirmed, holding that Appellant's claims were subject to the limitations period of Minn. Stat. Ann. Chapter 278 and were time-barred. View "Walmart Inc. v. Winona County" on Justia Law

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The Supreme Court affirmed the judgment of the district court denying Defendant's pretrial motion to strike down Minn. Stat. 624.714, subd. 1a, the permit-to-carry statute, and convicting Defendant of violating the statute, holding that the permit-to-carry statute does not violate the Second Amendment.Minn. Stat. 624.714, subd. 1a requires individuals to obtain a permit to carry a handgun in public. Defendant was charged with carrying a pistol in a public place without a permit in violation of the statute. Defendant filed a pretrial motion to strike down the permit-to-carry statute, arguing that the requirement that an individual obtain a permit to carry a firearm violates the Second Amendment. The district court denied the motion. The Supreme Court affirmed, holding that the permit-to-carry statute withstands strict scrutiny and does not violate the Second Amendment. View "State v. Hatch" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court finding Defendant guilty of violating a domestic abuse no contact order (DANCO), holding that the State did not violate Defendant's rights under the Minnesota Uniform Mandatory Disposition of Detainers Act (UMDDA).Defendant made a proper request for a final disposition under the UMDDA, and the State dismissed the charges pending against him. Nearly one year later, the State refiled the charges and brought Defendant to trial. The Supreme Court affirmed the resulting conviction, holding (1) once the State dismissed the pending complaint, Defendant no longer enjoyed a right to disposition of that complaint under the UMDDA; (2) the delay between Defendant's speedy trial request and his trial did not violate his constitutional right to a speedy trial; and (3) the district court did not abuse its discretion by declining to dismiss the State's complaint under Minn. R. Crim. P. 30.02. View "State v. Mikell" on Justia Law

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The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's conviction of theft under a principal theory of criminal liability and of being an indelible person in possession of a firearm, holding that the district court erred when it failed to conduct a Confrontation Clause analysis surrounding the testimonial statement of a nontestifying co-conspirator, but the error was harmless.On appeal, Defendant argued that the district court violated his right to confrontation by admitting his co-conspirator's statements to the police when Defendant had no opportunity to cross-examine his co-conspirator. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the district court violated Defendant's right to confrontation when it admitted the disputed statements into evidence at trial; but (2) the violation of the Confrontation Clause was harmless beyond a reasonable doubt. View "State v. Sutter" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction, holding that the State's discovery motion at Defendant's first court appearance seeking to photograph transitory scratches on Defendant's arms was not a critical stage of the criminal proceeding that required the presence of defense counsel.At Defendant's first appearance on criminal sexual conduct charges the State made a discovery motion to take photographs of transitory scratch marks on Defendant's arms. At issue was whether the discovery motion was a critical stage of the proceedings entitling Defendant to have counsel present. The court of appeals concluded that the discovery hearing on the "otherwise-valid" discovery request to noninvasively photograph scratches was not a critical stage of the proceedings. The Supreme Court affirmed, holding that there was no violation of Defendant's Sixth Amendment right to counsel under the circumstances of this case. View "State v. Zaldivar-Proenza" on Justia Law

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The Supreme Court reversed the decision of the court of appeals concluding that the United States Supreme Court's decision in Missouri v. McNeely, 569 U.S. 141 (2013), is substantive in the context of a conviction for test refusal, holding that the rule announced in McNeely is procedural and does not apply retroactively to test-refusal convictions on collateral review.In 2010, Defendant was convicted of first-degree test refusal for refusing to submit to a warrantless blood and urine test. In 2016, he filed a petition for postconviction relief, arguing that his conviction was unconstitutional. The district court ultimate determined that Defendant was entitled to postconviction relief, regardless of whether McNeely applied. The court of appeals reversed, holding that McNeely applied retroactively. The Supreme Court reversed and remanded the case, holding that McNeely did not apply retroactively to Defendant's test-refusal conviction, and the district court not properly articulate the pre-McNeely standard for exigent circumstances. View "Johnson 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 Appellant's petition for postconviction relief after determining that his stay of adjudication and discharge from probation was not a conviction, holding that Appellant's stay of adjudication was not a conviction.Pursuant to a plea agreement, Appellant pleaded guilty to domestic assault-intentional infliction of bodily harm. The district court accepted Appellant's plea of guilty and stayed adjudication under the parties' agreement. After Appellant successfully completed and was discharged from probation he received notice that he was scheduled for immigration removal proceedings. Appellant filed a petition for postconviction relief seeking to withdraw his guilty plea on grounds that he received ineffective assistance of counsel under Padilla v. Kentucky, 559 U.S. 356 (2010). The postconviction court concluded that Appellant had not been convicted of a crime and was therefore not eligible for postconviction relief. The Supreme Court affirmed, holding (1) the plain meaning of the phrase "a person convicted of a crime" in Minn. Stat. 590.01, subd. 1 means a person who has a conviction under Minnesota law; and (2) Appellant's stay of adjudication did not meet this definition. View "Johnston v. State" on Justia Law