Fallon Kelly

In State v. Bettin, the defendant was acquitted of two counts of first-degree criminal sexual conduct but convicted by a jury of the lesser-included offense of third-degree criminal sexual conduct under Minn. Stat. § 609.344(c) (1978), which requires penetration by force or coercion, and was sentenced to up to 10 years in prison. The defendant appealed, arguing that the evidence of force or coercion was insufficient, that the trial court erred in allowing the state to impeach him with a prior rape conviction if he testified, and that a mistrial should have been granted due to the jury possibly seeing him handcuffed to a witness in prison attire. The Minnesota Supreme Court affirmed the conviction, holding that the complainant's testimony and corroborating evidence of injuries and semen were sufficient to support the verdict, that the prior conviction's probative value for credibility outweighed its prejudice under Minn. R. Evid. 609(a), and that any potential jury observation of restraints or attire did not warrant a mistrial. A dissent argued that the prior conviction, being for similar conduct without elements of dishonesty, should have been excluded to avoid undue prejudice.

criminal lawprocedure

The case involved a defendant convicted of possessing cocaine and a handgun without a permit after police stopped him based on a bulletin and searched his car, finding a gun under the seat and later cocaine. The defendant argued the evidence should be suppressed as the product of an illegal search. The Minnesota Supreme Court affirmed the convictions, holding that the officers had reasonable suspicion to stop the defendant and that the search under the car seat was a permissible protective frisk under Terry v. Ohio to ensure officer safety.

criminal lawprocedureguns

The consolidated cases involved negligence claims against the State of Minnesota arising from two pre-1976 traffic accidents allegedly caused by defective highway and bridge designs. In Peterson v. Stanek, the trial court dismissed the claims on governmental immunity grounds; in Anderson v. City of Minneapolis, the trial court granted judgment notwithstanding the verdict to the State after a jury found it 34 percent negligent. The Minnesota Supreme Court reversed both dispositions, holding that common-law state immunity for torts before August 1, 1976, did not bar suits where a highway plan was so obviously dangerous that no reasonable person would approve it. The court reasoned that exceptions previously recognized for municipal highway liability, as set out in Paul v. Faricy, applied equally to the State because no justification existed for treating state and local governments differently in this context.

torts & liability

The case involved defendant Clark's petition for post-conviction relief after his conviction for the first-degree murder of Barbara Jiminez, raising claims including improper admission of evidence from a related trial, suppression of discovery materials, unlawful arrest and searches, improper prosecutorial arguments, and insufficiency of the evidence. The district court denied relief on all grounds, and the Minnesota Supreme Court affirmed that order. The court held that the defendant's prior testimony from the related trial of the victim's husband was admissible, that a statement overheard by a sheriff was not improperly obtained, and that the evidence was sufficient to support the conviction because the circumstances were inconsistent with any rational hypothesis of innocence. Many other issues were resolved by reference to the companion case, Clark I.

criminal law

This case involved a paternity action in which a jury found the defendant to be the father of the plaintiff's child, leading to an order for support; the defendant appealed the denial of his post-trial motion, claiming that the trial judge's questioning of a key defense witness undermined the fairness of the trial. The Minnesota Supreme Court reversed the judgment and remanded for a new trial. The court reasoned that while judges may examine witnesses under the rules of evidence, they must exercise great caution in doing so when witness credibility is central, as the judge's actions here could have improperly influenced the jury on a disputed factual issue in a paternity case. The opinion also emphasized that blood tests, which were not used, would have reduced reliance on credibility assessments and might have avoided the need for reversal.

family lawprocedure

The case involved a defendant charged in a single prosecution with both an open bottle law violation and driving while under the influence arising from the same traffic incident. After the unrepresented defendant pleaded guilty to the open bottle charge and was sentenced, the trial court convicted him of DUI on stipulated facts but deferred sentencing. The Minnesota Supreme Court determined that the offenses arose from the same behavioral incident under Minn. Stat. § 609.035, barring multiple punishments, but held that the single prosecution permitted the DUI conviction to stand even though sentencing on it was prohibited. The court reversed the district court's order vacating the DUI conviction, reasoning that the defendant's guilty plea caused the fragmentation and the state was not engaging in serialized prosecution.

criminal lawprocedure