Justia Constitutional Law Opinion Summaries

Following a bench trial, Keonne Palmer was found guilty of first-degree premeditated murder, second-degree intentional murder, and possession of a firearm by a prohibited person. Palmer appealed. The Supreme Court affirmed, holding (1) the circumstantial evidence in this case led to the conclusion that Palmer considered, planned, and prepared for the victim's death, and therefore, the evidence was sufficient to support a conviction of premeditated murder; (2) any failure by the district court to consider lesser-included manslaughter offenses could not have affected Palmer's substantial rights because the inclusion of manslaughter charges would not have affected the outcome; and (3) the trial court did not improperly pronounce Palmer's sentence.

After a jury trial, Brett Borg was found guilty of third-degree criminal sexual conduct. During the trial, the district court allowed a police officer to testify in the State's case in chief that Borg did not respond to a request for an interview by the officer. The court of appeals reversed Borg's conviction, concluding that the district court erred when it allowed the officer to testify about "silence in response to police questions or attempts to pose questions." The Supreme Court reversed the court of appeals and affirmed Borg's conviction, holding that the Fifth Amendment does not prohibit the State from introducing evidence during the State's case in chief regarding a defendant's silence unless the government compelled the defendant to speak or remain silent.

William Jacobs was charged with two counts of criminal sexual conduct. Jacobs moved to remove the judge assigned to his case for cause, basing his motion on the fact that the judge had not disclosed that his spouse was, at the time, an attorney with the county attorney's office that was prosecuting the case. Jacobs' motion was denied. The court of appeals denied Jacobs' writ of prohibition, holding that a spouse's position as an assistant county attorney in the public office that is prosecuting the case does not by itself create an appearance of partiality. The Supreme Court affirmed, holding that the judge was not required to disqualify himself from the case because a reasonable examiner, with full knowledge of the facts and circumstances in this case, would not question the judge's impartiality.

Following a jury trial, Lawrence Montanaro was convicted of first-degree murder of a police officer. After the statute of limitations for filing a postconviction petition expired, Montanaro filed a petition for postconviction relief. The postconviction court denied the petition without deciding whether Montanaro established an exception to the statute of limitations. The Supreme Court affirmed, holding that the postconviction court did not abuse its discretion in denying Montanaro's request for a new trial based on the court's conclusion that alleged errors in the jury instructions and the prosecutor's alleged misconduct during his closing argument did not satisfy the third prong of the plain error test because the errors did not affect Montanaro's substantial rights.

Appellant Victor Martinez-Mendoza was charged by complaint with one count of first-degree criminal sexual conduct and one count of second-degree criminal sexual conduct. The State and Appellant reached a plea agreement in which Appellant would plead guilty to count two of the complaint and count one would be dismissed. Appellant subsequently pleaded guilty to count two, and the district court adjudged Appellant guilty of count two. Before the sentencing hearing, the State learned that the actual presumptive guidelines sentence for the count two offense involved a much shorter incarceration time than the parties had originally thought. The State moved to vacate the plea or, in the alternative, reinstate count one of the complaint. The district court denied the motion, citing double jeopardy concerns. The court of appeals reversed based on the parties' mutual mistake. The Supreme Court reversed, holding that jeopardy attached when the trial court accepted and recorded Appellant's guilty plea, and thus, any appeal by the State was barred as moot as a matter of law.

Lincoln Caldwell was convicted in district court of aiding and abetting first-degree premeditated murder for the benefit of a gang. Caldwell appealed his conviction and the denial of two postconviction petitions. The Supreme Court affirmed, holding that (1) Minn. Stat. 609.05 permits the conviction of a defendant for aiding and abetting first-degree murder notwithstanding the fact that the party who fired the shots that killed the victim was acquitted of first-degree murder and convicted of second-degree murder; (2) there was sufficient evidence for the jury to conclude that the party who fired the shots that killed the victim had the necessary intent and premeditation to sustain Caldwell's conviction; and (3) there was sufficient evidence that a group of persons with whom Caldwell associated, and for whose benefit he committed the crime of first-degree murder, was a statutorily-defined gang.

After a jury trial, the district court convicted Ronald Hill of first-degree premeditated murder. The Supreme Court affirmed Hill's conviction, holding (1) because the district court properly and carefully balanced the potential probative value and prejudicial effects of the proffered impeachment evidence, the court did not abuse its discretion when it admitted evidence of Hill's prior, unspecified felony conviction for impeachment purposes; (2) Hill was not entitled to a new trial because allegedly improper testimony that the State obtained Hill's DNA sample through a search warrant was harmless because it did not affect Hill's substantial rights; (3) any alleged error in admitting evidence that Hill shot the victim with a gun stolen during a home invasion was harmless because there was not a reasonable possibility that the alleged error significantly affected the verdict; and (4) the cumulative effect of any errors resulting from the admission of disputed testimony did not affect Hill's substantial rights, and therefore, Hill was not deprived of his constitutional right to a fair trial.

Elizabeth Hawes was convicted of aiding and abetting her brother, Andrew Hawes, in the first-degree murder of their brother, Edwin Hawes. The district court sentenced Hawes to life imprisonment. The Supreme Court affirmed Hawes' conviction, holding (1) the circumstantial evidence was legally sufficient to support Hawes' conviction of aiding and abetting first-degree premeditated murder; (2) any error the the district court made when it ruled that out-of-court statements made by Andrew were not admissible as declarations against penal interest was harmless beyond a reasonable doubt; and (3) the district court did not abuse its discretion when it denied Hawes' motion for a new trial on the grounds of newly available evidence.

Diane Cox was charged with issuing dishonored checks with a value of more than $500 in violation of the dishonored-check statute, which is a felony. Cox filed a motion to dismiss, arguing that the sentencing disparity between the dishonored-check statute and the theft-by-check statute violated her constitutional right to equal protection of the law because issuing a dishonored check is a lesser-included offense of theft-by-check yet is punished more harshly than the greater offense. The district court denied Cox's motion but certified to the court of appeals the question of whether the disparity in the severity of punishment between the two statutes, which arguably contemplate the same acts committed under the same circumstances by persons in like situations, constitutes an equal protection violation as applied to defendant and those similarly charged. The appellate court answered the question in the negative. The Supreme Court affirmed, holding that Cox is not similarly situated to a defendant who commits theft by check because her conduct would not support a conviction for theft by check, and therefore Cox was not denied equal protection of the law.

In district court, appellant was convicted of aiding and abetting first-degree premeditated murder. At issue was whether the district court erred when it denied appellantâs pretrial motion to suppress statements made to law enforcement officials after appellant allegedly invoked his state and federal constitutional rights to remain silent and to have counsel present during custodial interrogation. The Supreme Court affirmed, holding (1) an invocation of the right to remain silent is ambiguous if the suspectâs statement could be interpreted as either a general refusal to answer any questions or as an expression of unwillingness to discuss a specific topic, and (2) when a suspect makes an equivocal invocation of the right to counsel, providing the suspect with a Miranda warning is sufficient as a matter of law to satisfy Minnesotaâs âstop and clarifyâ rule.