Helen M. Meyer

This case concerned a Minnesota school district's refusal to discuss in a disabled student's IEP meetings the supplementary aids and services needed for participation in extracurricular activities such as volleyball, clubs, and a graduation party. The Minnesota Department of Education found the district violated the federal IDEA by declining to consider those services, and the school district appealed. The Minnesota Supreme Court held that IDEA regulations (34 C.F.R. §§ 300.107, 300.117) require IEP teams to consider supplementary aids and services for a broad range of extracurricular and nonacademic activities without limiting them to only those required for the student's education. The court reasoned that the regulation's plain language enumerates numerous activities without such a restriction, the statute contains no such limit, and the regulation is within the Secretary of Education's authority and not ultra vires.

civil rightsfederal power

In State v. Cao, the defendant was convicted of third- and fourth-degree criminal sexual conduct after evidence showed he had intercourse with a complainant who was physically helpless from intoxication at a party. The prosecutor stated in closing argument that Minnesota law does not require corroboration of the complainant's testimony. The court of appeals held this constituted plain error and prosecutorial misconduct, but the Minnesota Supreme Court reversed and remanded, concluding the statement did not violate case law or rules so was not plain error, and that even assuming error it did not affect substantial rights because the evidence was strong, the comment was isolated, and the defense had rebuttal opportunities.

criminal lawprocedure

The case involved Stafon Edward Thompson, who was convicted by a jury of two counts of first-degree premeditated murder and two counts of first-degree murder while committing aggravated robbery for the deaths of Katricia Daniels and her son. Thompson appealed his convictions and consecutive life sentences, arguing that the district court erred in admitting certain statements he made to police and computer-generated crime scene images, that his trial counsel was ineffective, and that his sentences constituted cruel and unusual punishment given his age of 17. The Minnesota Supreme Court affirmed the convictions, holding that any errors in the admission of evidence were harmless and that the sentences did not violate constitutional protections.

criminal lawprocedure

The case concerned a 14-year-old who pleaded guilty in juvenile court to first-degree murder and attempted first-degree murder and was convicted and sentenced as an adult without a certification hearing or the findings required to transfer the case to adult court. The Minnesota Supreme Court held that the juvenile court's convictions and sentences were void for lack of subject-matter jurisdiction because the court made no findings on public safety or the statutory certification factors under Minn. Stat. § 260B.125. The court reversed the denial of postconviction relief and remanded for further proceedings, emphasizing that the juvenile court could not simply accept the guilty plea and impose adult sentences without satisfying the prerequisites for adult certification.

criminal lawprocedure

Gary Roby was convicted in 1989 of first-degree premeditated murder for the shooting death of Marlizza McIntyre and received a mandatory life sentence; his direct appeal and two earlier postconviction petitions were denied. In 2009 he filed a third petition alleging newly discovered evidence, including a letter and affidavits suggesting a co-conspirator was the actual shooter, and invoking the newly-discovered-evidence and interests-of-justice exceptions to the two-year filing deadline under Minn. Stat. § 590.01, subd. 4(b). The postconviction court dismissed the petition as untimely without examining whether any exception applied. The Minnesota Supreme Court reversed, holding that Roby had sufficiently invoked two statutory exceptions, and remanded for the postconviction court to determine whether the claims satisfied the time limits in subdivision 4(c) and, if so, whether they warranted relief.

criminal lawprocedure

Brett Arnold Laine was convicted of first-degree domestic abuse murder for killing his girlfriend, Nancy Jagunich, after evidence showed her injuries were inconsistent with his claim that she fell down stairs. Following affirmation of his conviction on direct appeal, Laine filed a second petition for postconviction relief alleging newly discovered evidence, ineffective assistance of counsel, and a Sixth Amendment Confrontation Clause violation based on out-of-court statements. The district court denied the petition without a hearing, and the Minnesota Supreme Court affirmed, holding that most claims were Knaffla-barred because they were known but not raised on direct appeal, the new evidence did not satisfy the criteria for granting relief, and Giles v. California did not render the statements testimonial or inadmissible.

criminal lawprocedure