Justia Constitutional Law Opinion Summaries

The State filed a delinquency petition against Appellant, alleging that Appellant committed second-degree intentional murder. The juvenile court certified the proceeding to adult court. Appellant was charged in district court with second-degree intentional murder. The complaint was amended to include second-degree felony murder. The jury found Appellant guilty of second-degree felony murder and second-degree manslaughter. Appellant appealed, arguing that the district court lacked subject-matter jurisdiction over the amended charge of second-degree felony murder and the lesser-included offense of second-degree manslaughter. The court of appeals affirmed, holding (1) the district court had jurisdiction over the charge specified in the certification order and other charges arising out of the same behavioral incident; and (2) the certification process did not violate Appellant's right to procedural due process. The Supreme Court affirmed, holding (1) a "proceeding" permitted by statute includes non-enumerated offenses arising out of the same behavioral incident as the offense enumerated in the certification order; and (2) following a valid certification order, a child no longer has a liberty interest in a juvenile adjudication for offenses arising out of the behavioral incident certified to adult court, and therefore the district court is not required to conduct another hearing on the certification issue.

Defendant was convicted of one count of felony harassment/stalking following a plea agreement. Defendant sought to apply jail credit to his harassment/stalking conviction sentence even though the jail credit claim was based on time Defendant spent in custody on an unrelated parole violation. When the district court sentenced Defendant, the court implicitly denied Defendant any credit for time spent in custody on the parole violation. The postconviction court held that Defendant was not entitled to any jail credit because the police did not have probable cause to arrest Defendant on the harassment/stalking charge until after he was released from prison on the parole violation. The court of appeals affirmed on different grounds. The Supreme Court also affirmed but on different grounds, holding that Defendant was not entitled to apply to his felony harassment/stalking sentence the jail credit he claimed for time spent in custody on the unrelated parole violation because, while in custody, the State had not completed its investigation into the harassment/stalking offenses, and it was not after Defendant was released from custody that the State had both probable cause and sufficient evidence to charge him with the harassment/stalking offenses with a reasonable likelihood of convicting him of those offenses.

Petitioner was convicted of first-degree murder committed for the benefit of a gang and attempted first-degree murder committed for the benefit of a gang. The Supreme Court affirmed Petitioner's convictions. Petitioner subsequently filed a petition for postconviction relief, claiming several violations of his right to counsel. The postconviction court denied Petitioner's petition without a hearing. The Supreme Court affirmed the decision of the postconviction court, holding that Petitioner was not entitled to postconviction relief on his claims of ineffective assistance of appellate counsel when his petition did not identify any prejudice resulting from the failure of Petitioner's counsel to raise specific challenges o the State's evidence and did not identify any federal constitutional claims that counsel unreasonably failed to raise.

Appellant was charged with three counts of fourth-degree controlled substance crime and one count of possession of a firearm by an ineligible person. A public defender was appointed to represent him. Prior to trial, the chief public defender made a motion seeking a discharge of the public defender and an order that Defendant had forfeited his right to counsel by manipulating the court and making threatening statements to his lawyer. After an evidentiary hearing at which Defendant was present but not represented by counsel, the court granted the motion, holding that Defendant had forfeited his right to counsel due to his severe misconduct. Defendant subsequently appeared pro se at his jury trial. The jury found him guilty of all counts. The court of appeals affirmed. The Supreme Court reversed in part, holding that the district court denied Defendant his procedural due process rights. The Court remanded the case to the district court for an evidentiary hearing, at which Defendant would be entitled to due process protections, to determine whether Defendant engaged in "extremely serious misconduct" warranting forfeiture of his right to counsel.

Defendant was convicted, after a stipulated facts bench trial, of first-degree possession of a controlled substance. More than five years after his conviction became final, Defendant filed a petition for postconviction relief. The postconviction court denied Defendant's petition as untimely and meritless. The court of appeals affirmed. The Supreme Court affirmed, holding (1) Appellant's petition was untimely under Minn. Stat. 590.01, 4(c), which requires that a claim is brought within two years from the time the claimant knew or should have known that the claim existed; and (2) section 590.01, subdivision 4 was not unconstitutional as a violation of the separation of powers doctrine where the legislature did not intrude unto a judicial function when it enacted the time limitations provisions in the postconviction statute.

Appellant Alexander Miller pleaded guilty to intentional second-degree murder of Crystal Lindorff by an Alford plea on March 11, 2005. Appellant's conviction was not reviewed on direct appeal. On May 11, 2009, Appellant filed this petition for postconviction relief. The postconviction court denied Appellant's petition, concluding that it was untimely and meritless. The court of appeals affirmed. The Supreme Court affirmed, holding that the postconviction court properly dismissed Appellant's postconviction petition, as (1) because Appellant filed the petition over two years after his claim arose, the petition was untimely; and (2) the time limits were constitutionally applied to Appellant's petition.

Appellant was convicted of first-degree premeditated murder and first-degree murder while committing criminal sexual conduct. Appellant filed a notice of direct appeal, which the Supreme Court stayed pending postconviction proceedings in the district court. Appellant neither filed a petition for postconviction relief nor followed through with his direct appeal, and the Court dismissed his appeal. In this case, Appellant appealed the denial of his first petition for postconviction relief. The Supreme Court affirmed, holding (1) the postconviction court properly denied Appellant's petition as untimely under Minn. Stat. 590.01, 4(a); and (2) the time limit in section 590.01, 4(a) was constitutional as applied to Appellant, because even if the Due Process Clause of the Minnesota Constitution provided Appellant a right to one review, the two-year time limitation in subdivision 4(a) was a reasonable limitation on the alleged right.

Respondent Christian Ndikum was charged with possession of a pistol in public after he carried a briefcase containing a gun into a courthouse. At trial, Respondent requested that the district court instruct the jury that knowledge of possession is an element of the crime of possession of a pistol in public that the State must prove. The district court refused to so instruct the jury, and the jury found Respondent guilty as charged. The court of appeals reversed, concluding that the State had to prove knowledge of possession of a pistol as an element of the crime of possession of a pistol. The Supreme Court affirmed, holding (1) the State was required to prove that Respondent knew he possessed the pistol at issue; and (2) the district court abused its discretion by failing to so instruct the jury.

After a grand jury indicted Defendant on two counts of first-degree premeditated murder, two counts of first-degree felony murder, and two counts of second-degree murder, the district court convicted Defendant on both counts of first-degree premeditated murder. Defendant challenged his convictions on four grounds. The Supreme Court affirmed, holding (1) the district court did not err in denying Defendant's motion for dismissal of the indictment; (2) the record contained sufficient evidence to support the district court's verdict that Defendant was guilty of first-degree premeditated murder rather than heat-of-passion manslaughter; (3) the prosecutor's alleged misconduct during witness questioning did not affect Defendant's substantial rights under the plain-error test; and (4) the allegedly erroneous admission of a witness's out-of-court statement did not substantially influence the district court's verdict, and therefore, Defendant was not entitled to a new trial.

Jerrell Brown was convicted of aiding and abetting first-degree murder for the benefit of a gang in connection with a shooting death. On appeal, Brown (1) challenged his conviction, claiming that the trial court violated his right to a public trial and erred in its evidentiary rulings and jury instructions, and (2) claimed the prosecutor violated his right to a fair trial by failing to disclose impeachment evidence. The Supreme Court affirmed Brown's conviction, holding (1) because the facts of this case did not implicate the right to a public trial, the trial court did not err in its evidentiary rulings or its jury instructions; and (2) the undisclosed impeachment evidence was not material.