February 7, 2024, Minnesota Supreme Court Caselaw Update
The Minnesota Supreme Court Releases Two Criminal Law Opinions:
State v. Snyder, A22-0318 -N.W.2d- (Minn. Feb. 7, 2024) (lifetime conditional release term and indictment requirement).
In Snyder, the supreme court concluded that the indictment requirement within Minnesota Rule of Criminal Procedure 17.01, subdivision 1, does not apply when the offense charged includes a sentence with a possible lifetime conditional release term. The supreme court concluded that, although a defendant who is placed on lifetime conditional release faces the possibility of a life sentence if the conditional release is revoked, this possibility is different than a sentence of life in prison because conditional release does not require a sentence of life in prison, unlike an actual life sentence. In sum, the State can charge a defendant with an offense that includes a possible lifetime without obtaining an indictment under Rule of Criminal Procedure 17.01.
OPA220318-020724 (mncourts.gov)
Greer v. State, A23-0915 -N.W.2d- (Minn. Feb. 7, 2024) (successive postconviction petitions following first-degree murder conviction)
In Greer, the supreme court reviewed the district court’s decision to summarily deny Greer’s fourth pro se petition for postconviction relief under the postconviction statute—Minnesota Statutes section 590.01. The supreme court had previously reviewed Greer’s first-degree murder conviction on direct appeal, following a remand to the district court, and following the district court denying Greer’s three petitions for postconviction relief. In this appeal, the supreme court ruled that the postconviction court did not abuse its discretion when it summarily denied Greer’s fourth petition for postconviction relief as time-barred because his allegations, even taken as true, were legally insufficient to justify relief.
