Justia Constitutional Law Opinion Summaries

When Appellant Amanda Tatro was a junior in the mortuary science program at the University of Minnesota, she posted statements on Facebook which she described as "satirical commentary and violent fantasy about her school experience." Following a hearing, the Campus Committee on Student Behavior (CCSB) found Tatro had violated the student conduct code and academic program rules governing the privilege of access to human cadavers, which prohibited "blogging" about cadaver dissection. CCSB imposed sanctions, including a failing grade for an anatomy laboratory course. The University Provost affirmed the sanctions. Tatro appealed, arguing that the University violated her constitutional rights to free speech. The court of appeals upheld the disciplinary sanctions. The Supreme Court affirmed, holding that the University did not violate the free speech rights of Tatro by imposing sanctions for her Facebook posts that violated academic program rules where the academic program rules were narrowly tailored and directly related to established professional conduct standards.

In a motion to withdraw his guilty plea, Respondent Reyes Campos argued the the U.S. Supreme Court's decision in Padilla v. Kentucky, which held that the Sixth Amendment right to counsel included the right to be informed about the deportation consequences of a guilty plea, applied retroactively to his conviction. Based on Padilla, Campos conended that his attorney's failure to warn him of the deportation consequences of his guilty plea constituted ineffective assistance of counsel and rendered his plea invalid. The district court determined that Padilla could not be applied to Campos' collateral attack on his conviction. The court of appeals reversed. The Supreme Court reversed, holding that Padilla announced a new rule of criminal procedure that does not apply to a collateral review of Campos' conviction. Remanded.

The State charged Brandon Smith with gross misdemeanor possession of a pistol without a permit and misdemeanor illegal transportation of a firearm. The charges resulted from Smith's possession of a pistol retrieved from his car by two state troopers during an otherwise lawful traffic stop. The district court convicted Smith of both charged offenses and sentenced him. The court of appeals vacated the misdemeanor sentence for illegal transportation of a firearm but affirmed the gross misdemeanor sentence of possession of a pistol without a permit. At issue on appeal was whether the district court erred by denying Smith's motion to exclude the pistol from evidence. The Supreme Court affirmed, holding that the troopers did not unlawfully expand the scope of the traffic stop without reasonable, articulable suspicion of illegal activity, and therefore, the district court did not err when it admitted the pistol into evidence.

Respondent Robert Half International (RHI) terminated Appellant Kim Hansen's employment shortly after she returned from maternity leave and failed to reinstate her to the same or similar position. Hansen filed an action against RHI, alleging that it violated the Minnesota Parenting Leave Act (MPLA) and the Minnesota Human Rights Act (MHRA) by failing to reinstate her to her position or a comparable position after maternity leave, for retaliating against her for taking maternity leave, and for terminating her because of her sex. The district court granted summary judgment in favor of RHI. The court of appeals affirmed. The Supreme Court affirmed, holding that there were no genuine issues of material fact and that judgment was appropriate as a matter of law.

Appellant Denon Rhoads was initially charged with a single count of second-degree burglary. At a pretrial hearing, Rhoads asserted his right to self-representation and signed a written waiver of counsel. The State later amended the complaint to include a count of first-degree burglary that roughly doubled the maximum possible punishment. On the day of trial, Rhoads renewed his waiver-of-counsel. The district court, however, did not conduct an on-the-record inquiry of Rhoads's understanding of the maximum punishment that might be imposed if he were convicted of first-degree burglary. Rhoads was later convicted of first- and second-degree burglary. The Supreme Court reversed Rhoads's first-degree burglary conviction and remanded, holding that because the record did not support an inference that when Rhoads renewed his waiver-of-counsel he understood the maximum possible punishment he faced had doubled, the renewed waiver-of-counsel was not knowing and intelligent. Remanded.

Nicole Beecroft was found guilty of first-degree premeditated murder for the stabbing death of her newborn baby. The key factual issue at trial was whether Beecroft's baby was alive or dead when stabbed by Beecroft. Each party presented testimony on this issue from medical examiners and other forensic pathologists, but certain state officials interfered with Beecroft's forensic experts. Beecroft subsequently filed a petition for postconviction relief, which the postconviction court denied. The Supreme Court reversed Beecroft's conviction, holding (1) the interference by the state officials undermined the integrity of the judicial system in this case; (2) the trial errors alleged by Beecroft did not in and of themselves warrant a reversal and the grant of a new trial; but (3) when the existence of alleged errors is combined with the improper conduct of state officials, a reversal is warranted in the interests of justice. Remanded for a new trial.

At issue in this appeal was how to calculate an offender's criminal history score when the court permissively imposes a felony sentence consecutive to a gross misdemeanor sentence. Respondent Tito Campbell was convicted of six offenses, including gross misdemeanor criminal vehicular operation resulting in bodily harm and felony fleeing a police officer resulting in death. The district court imposed a twelve-month sentence for the gross misdemeanor and a consecutive 234-month sentence for the felony fleeing offense, using a criminal history score of three. The court of appeals reversed Campbell's sentence, concluding that zero criminal history points should have been used to calculate the duration of the felony sentence. The Supreme Court reversed the court of appeals and reinstated the district court's sentence, holding that the district court's calculation of Campbell's sentence was correct.

Appellant Carol LaMont filed suit against her employer, a school district, for violations of the Minnesota Human Rights Act (MHRA). Appellant claimed that she had been subjected to a hostile work environment based on her sex and that she had suffered sexual harassment. The district court granted summary judgment to the school district on both claims, concluding that a hostile work environment based on sex was not actionable, and even if it were, Appellant had not established that the conduct of the school district's employees was sufficiently severe or pervasive. The court of appeals affirmed. The Supreme Court affirmed but under different grounds, holding (1) a cause of action for a hostile work environment based on sex is actionable under the MHRA; but (2) Appellant's allegations were insufficient to state a claim of hostile work environment.

Relator 78th Street OwnerCo, LLC, the owner and landlord of a hotel, filed petitions contesting Hennepin County's assessments of its property for property taxes payable in 2008 and 2009, along with the taxes due in 2008 and 2009. The tax court dismissed both petitions for failure to comply with the statutory sixty-day rule, which states that failure to submit required documentation within sixty days results in automatic dismissal of the petition, because each petition did not include a copy of 78th Street's lease and a calculation of percentage rent paid, and the 2008 petition did not include a rent roll/tenant list. The Supreme Court affirmed, holding (1) 78th Street's argument that the information it did not submit was not relevant to the calculation of property tax for its hotel property was unavailing because a taxpayer is not permitted to evaluate relevancy under the sixty-day rule, and neither the relevancy standard nor the unavailability exception excuses a taxpayer from providing required information that is available to the taxpayer; and (2) neither version of the sixty-day rule was unconstitutionally vague as applied to 78th Street.

After a jury trial, Chaun Carridine was convicted of first-degree premeditated murder and sentenced to life in prison. The Supreme Court affirmed, holding (1) the district court did not err by rejecting Carridine's challenges to the State's exercise of two peremptory strikes; (2) any error by the district court in allowing the State to impeach Carridine through his prior statement did not substantially influence the jury's verdict, and therefore, the error, if any, was not prejudicial; (3) the district court did abuse its discretion in instructing the jury; (4) in the instances where there was or may have been prosecutorial misconduct, the misconduct was either harmless or did not affect Carridine's substantial rights, and therefore, the objected-to prosecutorial misconduct was harmless.