Martin A. Nelson

In State v. Hoskins, the defendant was convicted after a jury trial of one count of second-degree murder and four counts of third-degree murder for killing his wife and children, then attempting to stage the scene as an attack by intruders by setting the house on fire and shooting himself. He appealed his convictions and the denial of a new trial, arguing primarily that the evidence, including expert testimony, established his insanity at the time of the offenses and that the jury should have been directed to acquit on that ground. The Minnesota Supreme Court affirmed the judgment, holding that the question of sanity was properly submitted to the jury, which was entitled to weigh the expert testimony along with other evidence and was not required to accept the defense experts' opinions as conclusive. The court found sufficient evidence in the record to support the verdicts returned.

criminal law

The case involved defendants charged under Minnesota Statute 617.241 with possessing obscene films with intent to sell at their Duluth bookstore, after police seized 54 reels pursuant to a warrant. A jury convicted them on 29 of 33 counts, resulting in per-count fines, and they appealed on issues of evidence sufficiency, exclusion of defense exhibits on community standards, First Amendment protections, and the statute's constitutionality for omitting an "utterly without redeeming social value" element. The Minnesota Supreme Court affirmed the convictions, holding that the jury could assess obscenity under the statutory definition without expert testimony and rejecting the constitutional claims, but modified the judgments to impose only a single fine because the counts stemmed from a single incident.

criminal lawfree speech

This case arose from a two-car collision at a rural intersection, where the plaintiff sued both drivers and their fathers as owners after settling with one pair of defendants for $10,500; the remaining issue was the cross-claims between the defendant groups over liability and contribution. The trial court found both drivers negligent as a matter of law and instructed the jury on proximate cause and superseding causation, resulting in a verdict that the Junkermeier driver's negligence was not a proximate cause of the accident. The court affirmed the denial of post-trial motions, holding that proximate cause is a jury question unless the evidence leaves no room for reasonable disagreement, and that the record supported the jury's conclusion either because the collision would have occurred anyway or because the other driver's actions were unforeseeable and superseding. The court also upheld the superseding-cause instruction as appropriate given the factual dispute.

torts & liability

This case involves a state prisoner's appeal from the denial of postconviction relief, in which he challenged the validity of his warrantless arrest and search, the voluntariness of his confessions and guilty plea to uttering a forged drug prescription, and the constitutionality of his indeterminate sentence of up to 20 years as cruel and unusual punishment under the Eighth and Fourteenth Amendments. The court affirmed the denial of relief. It held that a voluntary guilty plea waives challenges to prior defects in arrest, search, and confession under McMann v. Richardson, that the conviction for forgery does not violate constitutional prohibitions on punishing status as a drug addict under Robinson v. California and Powell v. Texas, and that the sentence within the statutory maximum was not cruel and unusual given legislative authority over penalties and the trial court's discretion.

criminal lawprocedurecivil rights

This case involved a nurse’s aide who developed back and leg pain during her employment at St. Barnabas Hospital and later sought workers’ compensation benefits. The employee did not inform her employer that the condition was work-related until more than a year after it began, and contemporaneous medical and insurance forms stated that any connection to employment was unknown or nonexistent. The Workmen’s Compensation Commission found that the employer had actual knowledge of the injury within the 90-day statutory period under Minn. St. 176.141, but the court reversed, concluding that knowledge of the disability alone did not constitute actual knowledge because it did not put the employer on inquiry notice that the injury arose out of employment. The court held that the commission’s finding lacked substantial evidentiary support in the record.

labor & employmentprocedure

In this case, the municipal court suppressed oral admissions made by the defendant to a police officer in a traffic violation prosecution because the prosecuting attorney served the Rasmussen notice on the defendant rather than his attorney. The state appealed the suppression order. The appellate court reversed with instructions to hold a Rasmussen hearing, determining that the state had acted in good faith by following local court rules when serving the defendant and that the error was harmless. It reasoned that remanding for a pretrial hearing on admissibility, with the defendant present and represented by counsel, would not unduly prejudice the defendant and would allow a proper determination of whether the evidence violated constitutional rights.

criminal lawprocedure