March 13, 2024, Minnesota Supreme Court Caselaw Update
Today, March 13, 2024, the Minnesota Supreme Court released opinions in two criminal cases.
First, in Kaiser v. State, A22-0749, (Minn. March 13, 2024), the supreme court affirmed the postconviction court’s decision reversing Kaiser’s second-degree murder convictions. Kaiser was convicted by a jury in Stearns County District Court of two counts of second-degree felony murder for the death of his 2-month-old son. The supreme court determined that the postconviction court correctly found that the State presented false expert testimony related to the cause of the child’s death.
The court concluded:
Here, the State’s experts made statements of medical fact to the jury that proved crucial in establishing Kaiser’s guilt. The district court conducted a thorough 9-day evidentiary hearing and gathered the facts necessary to conclude that the trial testimony was false. And the State’s own witness in effect recanted his trial testimony by saying later that it was incorrect. The unique cumulative effect of these facts shows that Kaiser’s trial was prejudiced by false testimony, and the district court therefore did not abuse its discretion by granting his petition for postconviction relief.
Stearns County; second degree felony murder
OPA220749-031324.pdf (mncourts.gov)
Second, in State v. Lehman, A22-0200 (Minn. March 13, 2024), the supreme court affirmed Lehman’s conviction for knowingly permitting a child to ingest methamphetamine. The supreme court granted review to determine whether the State must prove that a person charged with causing or permitting a child to ingest methamphetamine knew, at the time of the act, that the child was under the age of 18. See Minn. Stat. § 152.137, subd. 2(b) (2022). The court decided not to answer the question presented because the State’s evidence established that Lehman knew the child was under the age of 18.
The court concluded:
In accordance with the principle of judicial restraint, we do not address the statutory interpretation issue because the circumstantial evidence in this case . . . is consistent with a reasonable hypothesis that the defendant knew the victim was a child and inconsistent with any other rational hypothesis except that of guilt.
Stearns County; knowingly permitting a child to ingest methamphetamine
