February 21, 2024, Minnesota Supreme Court Caselaw Update
This week, the Minnesota Supreme Court released opinions in two criminal cases:
First, in State v. Ulrich, --N.W.3d--,2024 WL 696752 (Minn. Feb. 21, 2024), the supreme court affirmed Ulrich’s convictions for first-degree premeditated murder, attempted first-degree premeditated murder, and discharge of an explosive or incendiary device.
The supreme court rejected the three arguments Ulrich raised in his direct appeal.
1) The district court did not abuse its discretion when it denied Ulrich’s motion to strike a juror for cause because in the first step of the juror bias analysis, a juror is not required to affirmatively disavow bias even if actual bias is not otherwise established. The court also disagreed with Ulrich that the juror showed actual bias because the juror did not disclose any personal connection to the case, did not say that he had any special knowledge about the case, did not indicate a connection to anyone involved in the trial, and did not indicate that he would be predisposed to believing a particular witness’ testimony.
2) The district court did not abuse its discretion in denying Ulrich’s motion to change venue because he failed to renew his motion after jury selection and did not use a peremptory challenge to remove the one juror that may have been affected by adverse publicity.
3) The State presented sufficient evidence that Ulrich committed the charged offenses.
OPA221340-022124.pdf (mncourts.gov)
Second, in Townsend v. State—N.W.3d—, 2024 WL 697063 (Minn. Feb. 21, 2024), the supreme court concluded that the law-of-the-case doctrine bars relitigating an issue resolved earlier in the same case even if the issue presented is not raised in precisely the same way as it was previously raised. Townsend attempted, in different ways, to get jail credit applied to his life-with-the-possibility of release sentence connected to his first-degree murder conviction.
