Justia Constitutional Law Opinion Summaries

Appellant was convicted of aiding and abetting first-degree felony murder. The district court sentenced Appellant to life in prison. On appeal, Appellant claimed that numerous errors entitled him to a new trial. The Supreme Court affirmed Appellant's conviction, holding (1) the jury's verdict was unattributable to any error in admitting Appellant's statement recorded after he allegedly invoked his right to remain silent, and therefore, the admission of the statement into evidence was harmless; (2) the district court did not plainly err by allowing fear testimony at trial; (3) the district court did not abuse its discretion by not admitting certain hearsay statements; (4) the district court did not plainly err by giving a no-adverse-inerence jury instruction without Appellant's clear consent; and (5) Appellant was not entitled to a new trial based on the cumulative effect of the district court's errors.

Appellant was arrested and charged with first-degree premeditated murder. At trial, Appellant admitted shooting the victim, but claimed he did so in self-defense and without premeditation. The jury, rejecting Appellant's self-defense claim, found Appellant guilty of first-degree premeditated murder, and the district court sentenced Appellant to life in prison without the possibility of release. Appellant thereafter filed a petition for postconviction relief, which the postconviction court denied. The Supreme Court affirmed Appellant's conviction and the postconviction court's denial of postconviction relief, holding that each of Appellant's claims was either without merit or did not result in prejudice to Appellant.

In these two cases, Petitioners, members of the Minnesota Legislature and others, filed petitions pursuant to Minn. Stat. 204B.44 seeking an order requiring Mark Ritchie, the Minnesota Secretary of State, to use the titles designated by the Minnesota Legislature for two proposed constitutional amendment ballot questions that were scheduled to appear on the November 2012 general election ballot. Petitioners contended that by failing to use the title designated by the Legislature for each ballot question, Respondents failed to comply with the statutory requirement to "provide an appropriate title" for the ballot question. The Supreme Court granted the petitions, holding that when the Legislature has included a title for a ballot question in the bill proposing a constitutional amendment, the "appropriate title" the Secretary of State must provide for that ballot question is the title designated by the Legislature.

Appellant was convicted of first-degree murder while committing a drive-by shooting and drive-by shooting. The Supreme Court affirmed Defendant's conviction. In this case, Defendant appealed the summary denial of his second petition for postconviction relief, which alleged a claim of ineffective assistance of appellate counsel, and his third petition for postconviction relief, which alleged a claim of newly discovered evidence. The Supreme Court (1) affirmed the postconviction court's summary denial of the second postconviction petition because the record conclusively showed appellate counsel was not ineffective; but (2) reversed the court's summary denial of the third postconviction petition and remanded for an evidentiary hearing because the record failed to conclusively show that Appellant was not entitled to relief based on his claim of newly discovered evidence.

Defendant was found guilty by a jury of three counts of first-degree murder and three counts of second-degree murder. The district court entered convictions on the three counts of first-degree murder and imposed three consecutive life sentences. The Supreme Court affirmed Defendant's convictions on direct appeal. Defendant subsequently filed a second petition for postconviction relief, claiming he was entitled to an evidentiary hearing or a new trial based on newly discovered evidence. Defendant also brought a motion for additional fingerprint and forensic DNA testing. The postconviction court summarily denied the petition without an evidentiary hearing. The Supreme Court affirmed, holding (1) Defendant's petition was time-barred as a matter of law, and (2) the motion was not supported by adequate proof.

Respondent brought a claim against Appellants, the University of Minnesota and Orlando Smith, the University's men's basketball coach, alleging that Smith negligently misrepresented that he had authority to hire Respondent, and that Respondent suffered damage. The jury found in favor of Respondent and awarded damages. The court of appeals affirmed. At issue on appeal was whether the Supreme Court, as a matter of public policy, should extend the protection against negligent misrepresentation to prospective employees of the University, which is a constitutional corporation and agency of the state. The Supreme Court reversed, holding that when a prospective government employment relationship is negotiated at arm's length between sophisticated business persons who do not have a professional, fiduciary, or other special legal relationship, the prospective employee is not entitled to protection against negligent misrepresentations by the representative for the prospective government employer.

A jury found Appellant guilty of first-degree premeditated murder, first-degree murder while committing a kidnapping, second-degree intentional murder, and second-degree felony murder in connection with the stabbing death of his girlfriend. The trial court convicted Appellant of first-degree premeditated murder and sentenced him to life in prison without the possibility of parole. The Supreme Court affirmed Appellant's conviction, holding that, given the evidence of Appellant's planning activity, his motive, and the nature of the victim's killing, and given the reasonable inferences to be drawn from that evidence, the evidence of premeditation was sufficient to support Appellant's first-degree premeditated murder conviction.

A jury found Defendant guilty of falsely reporting an act of police misconduct under Minn. Stat. 609.505, subd. 2 (the statute) based on the fact that Defendant informed a police officer that another officer forged her signature, knowing that the information conveyed was false. The court of appeals reversed, concluding that the statute was unconstitutional because it criminalizes false speech critical of the police but not false speech that favors the police. The Supreme Court reversed, holding (1) the court of appeals erred in finding the statute unconstitutional because it criminalizes only defamatory speech not protected by the First Amendment and because it was within two of the exceptions to the constitutional prohibition against content discrimination in an unprotected category of speech; but (2) because Defendant's conviction under the statute preceded the Court's narrow construction of the statute, due process considerations entitled her to a new trial. Remanded.

At issue in this case was whether a statutory amendment to Minn. Stat. 253B.19, 2(d) effective in August 2010, applied to Appellant's November 2008 petition for provisional or full discharge from civil commitment as a sexually dangerous offender. Appellant argued that retroactive application of the amended statute to his petition was improper because the amendment introduced a new, higher burden for a petitioner seeking provisional or full discharge than the version of the statute that was operative when he filed his petition. The court of appeals affirmed the supreme court judicial appeal panel's decision to deny Appellant's petition. The Supreme Court affirmed, holding that the court of appeals properly evaluated Appellant's petition under the amended version of Minn. Stat. 253B.19, 2(d).

A jury found Appellant, Betsy Marie Hanks, guilty of first- and second-degree murder for the shooting death of her romantic partner. In preparation for trial, Hanks sought and received funding from the district court to hire an expert witness on battered woman syndrome. At trial, the district court granted the State's motion to prohibit the expert from testifying. After the guilty verdicts were returned, the district court convicted Hanks on both counts of murder. On appeal, Hanks asserted that the district court erred by excluding the battered woman syndrome expert testimony and by entering convictions on both first- and second-degree murder for a single act. The Supreme Court affirmed in part and reversed in part, holding (1) the district court did not err in excluding the expert testimony, as the evidence of a troubled relationship between Hanks her partner was insufficient to establish the type of relationship that would give rise to battered woman syndrome; and (2) the district court erred in convicting Hanks of both murder offenses. Remanded to the district court to vacate Hanks's conviction for second-degree murder.