Justia Constitutional Law Opinion Summaries

Appellant was convicted on six controlled substance crimes. The court of appeals affirmed Brist's convictions but remanded for the district court to modify Brist's sentence. On appeal, Brist argued that the admission of an audio recording of a statement made by her nontestifying coconspirator to a confidential government informant during a drug transaction violated her rights under the Confrontation Clause. The Supreme Court affirmed Brist's convictions, concluding that it was bound by Bourjaily v. U.S., which held that recorded statements of a nontestifying coconspirator, otherwise admissible as nonhearsay under materially identical evidentiary rules, are admissible at trial against another coconspirator without violating the Confrontation Clause. Therefore, the district court's admission into evidence of the coconspirator's statements in this case did not violate Brist's rights under the Confrontation Clause.

The State charged Ronald Fleck with second-degree assault after he stabbed his former girlfriend. During the trial, after all the evidence was presented to the jury, the district court submitted two forms of assault to the jurors, (1) assault-fear, prohibiting an act done with the intent to cause fear in another of immediate bodily harm or death, and (2) assault-harm, prohibiting the intentional infliction of bodily harm. The district court instructed the jurors that voluntary intoxication applied to an assault-fear offense but not an assault-harm offense. The jury found Fleck not guilty of second-degree assault-fear but guilty of second-degree assault-harm. The court of appeals reversed, concluding that the district court erred by failing to instruct the jury that voluntary intoxication applied to an assault-harm offense. The Supreme Court reversed the court of appeals' decision and reinstated Fleck's conviction, holding that the district court properly instructed the jury on the applicable law.

Appellant Herman Tanksley, Jr. was convicted of fourth-degree driving while impaired, which is driving with an alcohol concentration of 0.08 or more. Tanksley appealed, arguing that he was entitled to a Frye-Mack hearing on the reliability of first-void urine testing to resolve his claim that first-void urine testing does not reliably correlate with a driver's blood alcohol concentration. The court of appeals concluded that the district court abused its discretion in denying the Frye-Mack hearing to Tanksley but that the error was harmless. The Supreme Court granted transfer and affirmed the district court, holding that the district court was not required to hold a Frye-Mack hearing based on Tanksley's challenge, as blood alcohol concentration is irrelevant when the State seeks to prove the offense of driving with an alcohol concentration of 0.08 or more solely with evidence of the amount of alcohol in the defendant's urine.

Defendant Randolph Johnson was charged with felony domestic assault and misdemeanor fifth-degree assault. As part of a negotiated plea, Defendant pleaded guilty to an amended charge of misdemeanor domestic assault, and the State dismissed the felony charge. The district court ordered that Defendant submit to a DNA sample pursuant to Minn. stat. 609.117, subd. 1(1), which requires a defendant charged with a felony and then convicted of a misdemeanor arising out of the same set of circumstances to submit a DNA sample for the limited purpose of criminal identification, after concluding that the statute was constitutional as applied to Defendant. The Supreme Court affirmed after applying a totality-of-the-circumstances test, holding (1) the State's legitimate governmental interests in conducting a search of Defendant to collect a biological specimen for criminal identification purposes outweighed Defendants' reduced expectation of privacy following his misdemeanor conviction arising out of the same set of circumstances as his felony charge; (2) consequently, the statute did not violate the prohibitions against unreasonable searches and seizures in the state and federal constitutions; and (3) Defendant's equal protection claim failed.

Appellant, a juvenile, was petitioned for a felony and then adjudicated delinquent of a misdemeanor arising out of the same set of circumstances. The court ordered that Appellant provide a biological speciman to determine her DNA profile for the limited purpose of criminal identification after concluding that Minn. Stat. 609.117, subd. 1(2), which requires a juvenile adjudicated delinquent of a misdemeanor to submit a DNA sample, did not violate constitutional prohibitions against unreasonable searches and seizures and was not a denial of equal protection. The Supreme Court affirmed after applying a totality-of-the-circumstances test, holding (1) the State's legitimate governmental interests in collecting Appellant's DNA outweighed Appellant's reduced expectation of privacy following her misdemeanor adjudication arising out of the same set of circumstances as her felony petition; (2) consequently, as applied to Appellant, section 609.177, sub. 1(2) did not violate the prohibitions against unreasonable searches and seizures in the state and federal constitutions; and (3) Appellant's equal protection claim failed because Appellant was not similarly situated to misdemeanants without a felony petition, who were not required to provide a DNA sample under the statute.

Appellant Darryl Colbert was convicted of premeditated first-degree murder. The Supreme Court affirmed Colbert's conviction on direct appeal. Colbert subsequently filed five petitions for postconviction relief, and the postconviction court denied each petition. In this case, Colbert appealed the postconviction court's denial of his fifth petition for postconviction relief. The Supreme Court affirmed, holding that Colbert's petition was time-barred under Minn. Stat. 590.01, subd. 4, which states that a person seeking relief has two years from the disposition of the person's direct appeal to file a petition for postconviction relief, because it was filed more than two years after it arose.

Petitioners, including a state senator, filed a petition for writ of quo warranto challenging the authority of the county district court to authorize expenditures by any executive branch agency in the absence of legislative appropriations, the authority of the attorney general to seek authorization for such expenditures, and the authority of the commissioner of the Minnesota Department of Management and Budget to make payments for executive branch agency expenditures as authorized by the district court. The petition sought an order enjoining Respondents, including the attorney general, governor, commissioner, and chief judge of the district court, from seeking court orders that violated the state legislature's prerogatives to appropriate funds. In the meantime, the legislature passed, and the governor signed, appropriations for each state agency retroactive to the start of the biennium, and there were no further district court proceedings seeking funding. The Supreme Court found that the constitutional questions about the relative powers of the three branches of government were moot and would not arise again unless the legislative and executive branches failed to agree on a budget to fund a future biennium, and therefore, dismissed the petition as moot.

After a jury trial, Brett Borg was found guilty of third-degree criminal sexual conduct. The court of appeals reversed Borg's conviction, concluding that the district court erred when it allowed a police officer to testify in the State's case in chief that Borg did not respond to a mailed request for an interview by the officer. At issue on appeal was whether the Fifth Amendment prohibits the State from eliciting testimony during its case in chief regarding a criminal defendant's lack of response to a letter mailed to him by the police when the defendant was not under arrest or in custody and had not been informed of his Miranda rights. The Supreme Court reversed, holding that the district court did not err when it allowed the testimony because the Fifth Amendment does not prohibit the State from introducing evidence regarding a defendant's silence unless the government compelled the defendant to speak or to remain silent.

The Minnesota Board on Judicial Standards filed a formal complaint against Judge Patricia Karasov, judge of a district court, alleging violations of the Rules of the Code of Judicial Conduct and the Minnesota Constitution. A three-member panel appointed by the Supreme Court (1) found that Judge Karasov failed to reside within her judicial district during her continuance in office and failed to cooperate and be candid and honest with respect to the Board's investigation of her residency status, and (2) recommended that Judge Karasov be censured and suspended from judicial office for ninety days without pay. Both Judge Karasov and the Board appealed. The Supreme Court concluded (1) the Board proved by clear and convincing evidence that Judge Karasov committed judicial misconduct by clear and convincing evidence; (2) Judge Karasov's claim that she was denied due process of law by irregularities in the proceedings lacked merit; and (3) the appropriate judicial discipline was censure and suspension from judicial duties for six months without pay.

Appellant Mahdi Ali was indicted for murder in the first degree and murder in the second degree for the shooting deaths of three individuals. The indictment alleged that Ali was seventeen years old on the date of the alleged offenses and therefore automatically subject to trial in the district court. Ali moved to dismiss the indictment, contending that he was fifteen years old on the date of the shootings and that the jurisdiction of the juvenile court was therefore exclusive. The district court denied the motion, concluding that Ali had reached his sixteenth birthday before the date of the shootings. The court of appeals dismissed Ali's appeal, concluding that the district court's order denying Ali's motion to dismiss the indictment was not appealable. The Supreme Court reversed in part and affirmed in part, holding (1) the denial of a defendant's motion to dismiss an indictment for murder for lack of subject matter jurisdiction is immediately appealable as of right; and (2) when the age of the defendant determines the jurisdiction of the court, the State has the burden of proving, by a preponderance of the evidence, the defendant's age on the date of the alleged offense.