Justia Constitutional Law Opinion Summaries

Appellant Juan Humberto Castillo-Alvarez challenged his convictions for second-degree murder and kidnapping. Appellant contended that Minn. Stat. 609.045 (2012) and the Double Jeopardy Clause of the Minnesota Constitution bar the prosecution in this case. He also asserted that the district court erred in admitting evidence of his unrecorded statement to law enforcement. Because neither section 609.045 nor the Minnesota Constitution bar the prosecution and because the district court properly admitted appellant's unrecorded statement, the Supreme Court affirmed. View "Minnesota vs. Castillo-Alvarez" on Justia Law

Appellant Ronald Greer sought post-conviction relief from his murder conviction. The trial court denied relief, and he appealed that denial to the Supreme Court. Finding that the trial court did not abuse its discretion in denying Greer's petitions for relief, the Supreme Court affirmed. View "Greer v. Minnesota" on Justia Law

After a jury trial, Appellant was convicted of two counts of first-degree premeditated murder, two counts of first-degree felony murder, and three counts of first-degree aggravated robbery. The Supreme Court affirmed Appellant's convictions, holding that the district court did not err by (1) overruling Defendant's Batson objection to the State's peremptory challenge of an African-American prospective juror, as Defendant failed to prove that the challenge constituted purposeful racial discrimination; and (2) admitting evidence that Defendant assaulted and threatened a witness two days before trial to prove consciousness of guilt, as the district court correctly weighed the probative value of the evidence against the danger of unfair prejudice and provided safeguards to ensure the evidence would not unduly influence the jury's verdict. View "State v. Diggins" on Justia Law

Defendant, who was HIV positive, engaged in consensual anal intercourse. Defendant was subsequently charged with attempted first-degree assault by transferring a communicable disease for violating Minn. Stat. 609.2241(2). A jury found Defendant violated section 609.2241(2)(2), which applies to the "transfer of blood, sperm, organs, or tissue." The court of appeals reversed the conviction, concluding that section subdivision 2(2) applies only to medical procedures instead of applying to acts of sexual conduct. The Supreme Court affirmed, holding (1) subdivision 2(2) applies only to the donation or exchange for value of blood, sperm, organs, or tissue; and (2) because Defendant's conduct indisputably did not involve the donation or exchange for value of his sperm, subdivision 2(2) was inapplicable to Defendant's conduct. View "State v. Rick" on Justia Law

After a jury trial, Defendant was convicted of criminal vehicular homicide for causing the death of ninety-three-year-old Edith Schouveller in a motor vehicle accident. The accident occurred on March 28, 2010. Schouveller was transported to the hospital with several life-threatening injuries. For the next twenty-two days, Schouveller was either hospitalized or in a nursing home. Schouveller developed lung problems while in the hospital, which led to pneumonia. On April 19, 2010, Schouveller experienced acute respiratory failure. Doctors determined that she needed to be placed on a respirator in order to continue to live, but relying on Schouveller's living will, the doctors declined to place her on respiratory support. Schouveller died that evening. The Supreme Court affirmed Defendant's conviction, holding (1) the district court properly instructed the jury on causation; (2) the State presented sufficient evidence to demonstrate a causal chain between the injuries Shouveller sustained in the accident and the pneumonia and aspiration that ultimately led to her death; and (3) the evidence was sufficient for the jury to conclude that the do-not-resuscitate order in Souveller's living will was not a superseding cause of her death. View "State v. Smith" on Justia Law

A snowplow driver for the City of Alexandria collided with Donald Fernow's vehicle. Fernow brought a personal injury action against the City. At the same time, Fernow's insurance company (Insurer) sought arbitration against the City, seeking repayment in basic economic loss benefits paid to Fernow. In the personal injury action, the district court denied the City's motion for summary judgment on the basis that Fernow's claim was barred by statutory discretionary immunity, common law official immunity, and statutory snow and ice immunity. The court of appeals affirmed. Meanwhile, the arbitrator awarded Insurer basic economic loss benefits, concluding that the defense of governmental statutory immunity did not apply to the matter because of the denial of the City's motion for summary judgment. The district court confirmed the award. The court of appeals reversed, concluding that the arbitrator exceeded her authority when she determined that the defense of governmental statutory immunity did not apply to the matter. The Supreme Court affirmed on different grounds, holding that claims of immunity, including necessary questions of fact, should be determined by the district court prior to arbitration on the merits under the Minnesota No-Fault Automobile Insurance Act. Remanded. View "Fernow v. Gould" on Justia Law

After a jury trial in 1994, Defendant was convicted of first-degree murder and sentenced to life in prison with the possibility of release. Seven months later, Defendant pleaded guilty to second-degree attempted murder. The court sentenced Defendant to an additional seventy-two months in prison to run consecutively to his life sentence. In 2012, Defendant filed a pro se motion to correct his sentence under Minn. R. Crim. P. 27.03(9). The district court treated the motion as a petition for postconviction relief and then denied the motion on the grounds it was time barred and procedurally barred. The Supreme Court affirmed, holding that even if Defendant's motion was not time barred or procedurally, barred, his argument that the overall length of his imprisonment should be reduced failed on the merits. View "Townsend v. State" on Justia Law

After a jury trial, Defendant was convicted of nine counts, including one count of first-degree premeditated murder and two counts of attempted first-degree premeditated murder, stemming from an incident in which Defendant fired a semiautomatic rifle at Joseph Rivera and two of Rivera's friends. The Supreme Court affirmed, holding that the district court did not err when it (1) denied Defendant's pretrial motion to dismiss the indictment, as any alleged misconduct by the State did not substantially influence the grand jury's decision to indict; (2) admitted Defendant's taped statement to police, as the statement was voluntary made; (3) admitted a photograph of Rivera as a child, as the photograph was admissible as spark of life evidence; (4) denied Defendant's motion for a mistrial based on a law enforcement officer's testimony that Defendant was truant and once swore at a teacher in high school; and (5) denied Defendant's request for surrebuttal closing argument, because even if the district court erred in denying the request, the error was harmless beyond a reasonable doubt. View "State v. Morrow" on Justia Law

After a jury trial, Defendant was convicted of first-degree murder by drive-by shooting and first-degree premeditated murder. Defendant appealed, arguing that the trial court erred in admitting out-of-court statements made by his wife and cell phone records obtained without a warrant. The Supreme Court affirmed, holding (1) the district court did not abuse its discretion in admitting Defendant's wife's statement under Minn. R. Evid. 807; and (2) the district court did not err in finding Defendant had no subjective expectation of privacy in the cell phone records at issue under the Supreme Court's decision in State v. Gail, and therefore, the admission of the cell phone records did not violate Defendant's constitutional rights. View "State v. Griffin" on Justia Law

After a jury trial, Defendant was convicted of third-degree criminal sexual conduct and sentenced to forty-eight months in prison. As part of the sentencing order, the trial court ordered Defendant to pay restitution. More than ninety days after entry of the order imposing Defendant's initial sentence, the court amended the restitution portion of Defendant's initial sentence. The State appealed the amended sentencing order, but the court of appeals dismissed the appeal because it was not filed within ninety days after the initial imposition of Defendant's sentence. The Supreme Court reversed, holding (1) the issuance of an order amending the restitution portion of a sentence constitutes a "sentence imposed" within the plain language of the relevant statute, such that the State had ninety days to appeal the amended sentencing order from the date it was entered; and (2) because the State appealed the amended sentencing order within ninety days, the appeal was timely. Remanded. View "State v. Borg" on Justia Law