Justia Constitutional Law Opinion Summaries

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.

Appellant Dario Bonga pled guilty to first-degree premeditated murder less than one day after he confessed to killing Carlos San Miguel and attempted to kill himself while in custody awaiting trial. The district court accepted Appellantâs guilty plea, convicted him, and sentenced him to life in prison. Appellant filed a petition for post conviction relief in which he sought to withdraw his guilty plea, arguing that he was not competent to plead guilty. On appeal to the Supreme Court, Appellant argued that the district court did not give sufficient weight to evidence that suggested he was incompetent to plead when it sentenced him to life. Particularly, Appellant argued that the court should have ordered an examination and report on Appellantâs mental condition when it learned that Appellant attempted suicide the day before the hearing. The Supreme Courtâs review of the record revealed that on several occasions Appellant was offered counsel, dismissed counsel, sought to speak with the prosecutors, and asked to represent himself at trial. The record would also reveal that the trial court asked Appellant multiple times, on the record, whether he understood the nature of the charges against him and whether Appellant understood the risk he ran by representing himself. The Court was satisfied that the trial court gave Appellant every opportunity to seek counsel and preserve his legal rights. Finding no error, the Supreme Court affirmed Appellantâs conviction and sentence.