Justia Constitutional Law Opinion Summaries

The Supreme Court affirmed the judgment of the district court denying Defendant's petition for postconviction relief arguing that the rule announced in Miller v. Alabama, 567 U.S. 460 (2012), and later clarified in Montgomery v. Louisiana, 577 U.S. __ (2016), should be extended to adult offenders whose crimes reflect the transient immaturity of youth, holding that the district court did not abuse its discretion when it denied Defendant's postconviction petition.Defendant was convicted of first-degree premeditated murder and sentenced to a mandatory term of life in prison without the possibility of release. Defendant was eighteen years and seven days old on the date of the offense. On appeal from the denial of his postconviction motion, Defendant renewed his Miller/Montgomery argument and further asked the Supreme Court to interpret Minn. Const. art. I, 5 to provide greater protection than the Eighth Amendment. The Supreme Court affirmed, holding (1) because the Miller/Montgomery rule is clearly limited to juvenile offenders under the age of eighteen at the time of the offense, the district court did not abuse its discretion when it denied Defendant's petition for postconviction relief; and (2) Defendant forfeited appellate review of his claim under the Minnesota Constitution. View "Nelson v. State" on Justia Law

The Supreme Court affirmed the judgment of the district court and the court of appeals concluding that Minn. Stat. 609.27 subd. 1(4) was constitutionally overbroad and could not be saved through a narrowing construction or by severing part of it, holding that subdivision 1(4) criminalizes a substantial amount of protected speech and is thus unconstitutional on its face.Defendant was charged with one felony count of attempted coercion under section 609.275, the attempted coercion statute. Defendant filed a motion to dismiss, arguing that the statute was overly broad in violation of the First Amendment. The district court granted the motion to dismiss, and the court of appeals affirmed. The Supreme Court affirmed, holding that Minn. Stat. 609.27 subd. 1(4) is substantially overbroad and cannot be narrowed or saved by severance and therefore must be invalidated as violating the First Amendment. View "State v. Jorgenson" on Justia Law

The Supreme Court affirmed Defendant's convictions for of first-degree premeditated murder and attempted first-degree premeditated murder but reversed Defendant's 360-month sentence for attempted first-degree premeditated murder, holding that the sentence was error because it exceeded the statutory maximum.Specifically, the Supreme Court held (1) the district court did not abuse its discretion by denying Defendant's pretrial motion to suppress his post-Miranda statements; (2) the jury instruction on the elements of premeditated murder was not erroneous, and the district court did not err by failing to give a jury instruction on accomplice testimony; and (3) because the statutory maximum for the offense of attempted first-degree premeditated murder is 240 months, Defendant's sentence on this offense is remanded for resentencing. View "State v. Ezeka" on Justia Law

The Supreme Court affirmed the judgment of the district court determining that Appellant's claim of ineffective assistance of counsel failed under the second prong of Strickland v. Washington, 466 U.S. 668 (1984), holding that, even if Appellant had offered to plead guilty to second-degree murder, Appellant made no showing that there was a reasonable probability that the State would have entered into a plea agreement.A jury found Appellant guilty of first-degree murder while committing child abuse, second-degree felony murder, and second-degree manslaughter. Appellant later filed a postconviction motion, alleging that her counsel provided ineffective assistance by failing to recommend that she plead guilty to second-degree murder and by failing adequately to inform her about the power of the State's case. The district court concluded that Appellant had satisfied the first but not the second prong of Strickland. The Supreme Court affirmed, holding that, even assuming that defense counsel's recommendation could have persuaded Appellant to make a qualifying offer, Appellant failed to show that any such offer would have been accepted by the State and presented to the court. View "Peltier v. State" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the district court granting Defendant's motion to suppress evidence seized from his vehicle during a traffic stop, holding that a driver violates Minn. Stat. 169.30(b) by driving past the stop sign or stop line before coming to a complete stop.Defendant's vehicle was stopped after he failed to stop at a stop sign and stop line. The district court suppressed the evidence seized from Defendant's vehicle, concluding that the traffic stop was unlawful because Minn. Stat. 169.30(b) requires a driver "to stop at the intersection, not at the stop sign or stop line." The court of appeals reversed. The Supreme Court affirmed, holding (1) section 169.30(b) is violated when the driver a vehicle drives past the stop sign or stop line before coming to a complete stop; and (2) because Defendant failed to bring his vehicle to a complete stop before he drove his vehicle past the stop line and the stop sign, the traffic stop was lawful. View "State v. Gibson" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing Defendant's conviction on the ground that Defendant was denied effective assistance of counsel because, by conceding in the written closing argument elements of the crimes charged, Defendant's attorney conceded guilt without Defendant's consent or acquiescence, holding that no new trial was required.In reversing the conviction, the court of appeals reasoned that defense counsel's concession of one or more elements of a crime is a concession of guilt and that an unconsented-to concession requires a new trial. The Supreme Court reversed, holding (1) defense counsel's concessions of fewer than all of the elements was not a concession of guilt, and therefore, no new trial was required; and (2) counsel's concessions did not amount to trial error under Strickland v. Washington, 466 U.S. 668 (1984). View "State v. Huisman" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming Defendant's conviction of check forgery, holding that a government inspection of a guest registry is a search under the Minnesota Constitution and that the district court committed reversible error by admitting evidence illegally seized from Defendant's hotel room.Based on evidence that law enforcement officers discovered in Defendant's hotel room, Defendant was charged with check forgery. Defendant filed a motion to suppress, arguing that the officers violated Minn. Const. art. I, 10 when they inspected the hotel guest registry, which led them to his room, without having any individualized suspicion of criminalized activity. The district court denied the motion, and the court of appeals affirmed. The Supreme Court reversed, holding (1) law enforcement officers must have at least a reasonable, articulable suspicion to search a guest registry; (2) the hotel guest registry statutes, Minn. Stat. 327.10-.13 are constitutional because they do not authorize suspicionless searches; and (3) because the evidence admitted in this case was the fruit of the illegal, suspicionless search of the guest registry the district court erred by denying Defendant's motion to suppress. View "State v. Leonard" on Justia Law

The Supreme Court affirmed Defendant's convictions for first-degree murder and second-degree murder but reversed the sentence in part, holding that the district court erred by entering a formal adjudication on both first-degree murder and second-degree murder but any other error in the proceedings below was harmless.Specifically, the Supreme Court held (1) any error the district court may have made by declining to hold an evidentiary hearing regarding the admissibility of DNA evidence was harmless, and the district court did not abuse its discretion by denying Defendant's motion to exclude the DNA evidence; (2) Defendant was not prejudiced by alleged prosecutorial misconduct; and (3) the district court erred by entering a formal adjudication on both first-degree murder and second-degree murder in its sentencing order, and therefore, the cause must be remanded to the district court to correct the error. View "State v. Garland" on Justia Law

The Supreme Court affirmed Defendant's conviction for first-degree murder, holding that there was no error in the proceedings below.Specifically, the Supreme Court held (1) Appellant's right to a fair trial before an impartial tribunal was not violated when the district court stated that it might reconsider its prior Spreigl ruling if the defense presented certain witnesses; (2) the jury instructions on accomplice liability were plainly erroneous, but Appellant failed to establish that there was a reasonable likelihood that the error had a significant effect on the verdict; (3) the prosecutor did not commit misconduct in his closing arguments regarding the law of accomplice liability; (4) the district court did not abuse its discretion by granting the State’s motion to admit evidence of appellant’s past convictions for impeachment purposes, including by allowing the specific convictions to be disclosed to the jury; and (5) Appellant’s pro se arguments were without merit. View "State v. Reek" on Justia Law

The Supreme Court affirmed the decisions of the district court denying Appellant's ineffective assistance of trial counsel claim raised in his first petition for post conviction relief and the claims raised in his second petition for postconviction relief, holding that the district court did not abuse its discretion by denying Appellant's claims.After a jury trial, Appellant was found guilty of first-degree felony murder, attempted first-degree felony murder, and second-degree assault. The Supreme Court affirmed. In his first petition for postconviction relief, Appellant raised some of the same issues addressed in his direct appeal but also claimed that he received ineffective assistance of trial counsel. The district court ordered an evidentiary hearing only on the ineffective assistance of counsel claim and, after a hearing, denied the claim. Appellant then filed a second petition for postconviction relief, which the district court summarily denied. The Supreme Court affirmed both of the district court's orders, holding (1) Appellant did not satisfy the first prong of Strickland on his ineffective assistance of counsel claim; and (2) all of Appellant's claims in his second petition were time barred. View "Griffin v. State" on Justia Law