May 2026 | Legal Case Updates | Guilty Pleas, Search & Seizure, Aiding & Abetting Murder, and More

GUILTY PLEAS: HEIGHTENED INQUIRY INTO RISK OF COERCION IS REQUIRED BEFORE ACCEPTING A CONTINGENT PLEA

After he was charged with four felony controlled substance offenses, Appellant entered into a continent plea agreement, whereby he agreed to plead guilty to two offenses in exchange for dismissal of two others and leniency from the State in his wife’s corresponding controlled substance case. The district court accepted Appellant’s guilty plea without asking Appellant any questions about any potential coercion. The Court of Appeals affirmed Appellant’s conviction, concluding his contingent pleas were voluntary. The Supreme Court disagrees.

To be constitutionally valid, a guilty plea must be accurate, voluntary, and intelligent. To ensure a plea meets these requirements, certain specific inquiries are required of the district court under Minn. R. Crim. P. 15.01, including any promises offered in exchange for the defendant’s plea, as this inquiry may reveal the plea was involuntary. This is particularly relevant where a contingent plea is made—a guilty plea given in exchange for leniency for a third party. More than the standard inquiry is required of the court where a contingent plea is involved. The State must disclose all of the contingent terms, and the Supreme Court holds that the district court must ask questions of the defendant “targeting any possible coercion to ensure that, notwithstanding any contingency, a guilty plea is truly voluntary.”

In Appellant’s case, the court made no inquiries beyond the standard requirements of Rule 15.01. The proper remedy is to allow Appellant to withdraw his guilty plea. State v. Torrez, A24-0818, 34 N.W.3d 685 (Minn. May 6, 2026).

SEARCH AND SEIZURE: SUBJECTIVE INTENT OF POLICE IS IRRELEVANT FOR EMERGENCY AID EXCEPTION TO THE WARRANT REQUIREMENT

Police responded to a 9-1-1 call of an individual slumped in a vehicle lawfully parked on a street for approximately an hour, blocked the vehicle, and placed tire deflation sticks under itswheels. Appellant was found “slumped behind the wheel” with her head leaned back and was woken by police. After she completed field sobriety tests, police obtained a warrant to search her blood or urine, testing of which later revealed the presence of controlled substances. After she was charged with driving while under the influence, Appellant moved to suppress evidence obtained after the police seized her vehicle, arguing the seizure was not supported by reasonable, articulable suspicion of criminal activity, but the district court denied Appellant’s motion and she was convicted after a stipulated facts trial.

The parties agree Appellant was seized when police boxed in her vehicle and placed tired deflation strips under the wheels. The Court of Appeals agrees with Appellant that police did not have reasonable, articulable suspicion of criminal activity to justify this seizure. At the time of the seizure, police only knew Appellant was slumped in a legally parked car for a brief time. An officer testified that, in his experience, “slumped motorists may endanger people or property if they become startled upon waking and quickly drive away,” but the court finds this “generalized statement… does not amount to a particularized and objective basis for suspecting [Appellant] of being involved in criminal activity.”

However, the court finds the emergency aid exception to the warrant requirement did provide justification for the seizure. The emergency aid exception validates a warrantless search or seizure if police “have reasonable grounds to believe that there is an emergency at hand and an immediate need for their assistance for the protection of life or property” and “there is some reasonable basis, approximating probable cause, to associate the emergency with the area or place to be searched.” Consistent with courts that have considered this issue under the federal constitution, the court holds that, under Minnesota’s constitution, the subjective motive of the officers conducting the search or seizure is irrelevant to the emergency aid exception. Under these circumstances, as Appellant conceded, “a reasonable person would have believed an emergency existed,” and there is no dispute police had a reasonable basis to associate the emergency with Appellant.

The court also concludes that there was reasonable, articulable suspicion to support expanding the scope of the seizure to a DWI investigation, given the circumstances of the 9-1-1 call, the police officer’s experience with drug investigations and slumped motorists, and observations of Appellant’s slow physical and verbal responses once awoken by police. The district court did not err in denying Appellant’s motion to suppress. State v. Gale, A25-0834, 2026 WL 1278974 (Minn. Ct. App. May 11, 2026).

AIDING AND ABETTING MURDER: DENIAL OF A PETITION FOR RELIEF UNDER THE ACT OF MAY 19, 2023, FOLLOWING AN EVIDENTIARY HEARING WAS AN ABUSE OF DISCRETION

Appellant was convicted in 2004 of first-degree felony murder and attempted first-degree felony murder on an aiding and abetting theory of liability. In 2023, the aiding and abetting statute was amended to require proof that the defendant “intentionally aided, advised, hired, counseled, or conspired with or otherwise procured the other with the intent to cause the death of a human being.” Minn. Stat. § 609.05, subd. 2a(a). The Act of May 19, 2023 (“the Act”) established a pathway for challenging aiding-and-abetting felony murder convictions based on the previous version of section 609.05. The Act allows convicted individuals to file a preliminary application, and, if the court finds a reasonable probability the applicant is entitled to relief, the applicant may file a petition to vacate their conviction. The court may then grant the petition or deny it without an evidentiary hearing or hold an evidentiary hearing. After an evidentiary hearing, the petitioner is entitled to relief it they show by a preponderance of the evidence that they did not cause the death of a human being and did not intentionally aid, advise, hire, counsel, or conspire with or otherwise procure another with the intent to cause the death of a human being.

Appellant sought to vacate his convictions under the Act in 2024. He filed a preliminary application, then was permitted to file a petition to vacate his convictions. An evidentiary hearing was held, at which the court was asked to review the trial transcripts and other documentary records. The court denied Appellant’s petition, finding Appellant failed to prove by a preponderance of the evidence that he did not act with intent to kill.

The Supreme Court first holds that the proper standard of review of a district court’s denial of a petition for relief under the Act following an evidentiary hearing is abuse of discretion.

The court also finds the district court did not abuse its discretion here. The record supports the district court’s factual findings, the district court applied the proper standard in considering Appellant’s petition (preponderance of the evidence), and the district court independently evaluated the evidence in determining Appellant failed to meet his burden. The denial of Appellant’s petition for relief under the Act is affirmed. Green v. State, A25-0102, 35 N.W.3d 1 (Minn. May 13, 2026).

RIGHT TO CONFRONTATION: NO CONFRONTATION CLAUSE VIOLATION TO ADMIT TRANSCRIPT OF ADVERSE WITNESS’S PRIOR TESTIMONY WITHOUT DEFENDANT’S WAIVER

At Appellant’s first trial on charges of murder and assault, the State introduced testimony from the victim and an eyewitness, D.A. A mistrial was declared, and, at the second trial, theState was not able to procure D.A. to testify. With agreement from the State and the defense, the district court admitted a transcript of D.A.’s testimony from the first trial to be read to the jury. The jury convicted Appellant and he appealed, arguing the district court plainly erred by admitting D.A.’s testimony without a personal waiver of Appellant’s right to confront D.A. The Court of Appeals affirmed.

As Appellant did not object to the district court’s decision to admit D.A.’s prior testimony, reversal is required only if the decision was plain error. Without deciding whether the district court committed error, the Supreme Court holds that reversal is not required. The Confrontation Clause prevents testimonial hearsay evidence against a criminal defendant unless the adverse witness is unavailable and the defendant had a prior opportunity to cross-examine the witness’s testimony. This confrontation right may be waived, but the courts have not previously made clear whether the waiver need be made personally by the defendant.

Although the right to confrontation is a fundamental right, the U.S. Supreme Court has previously indicated in dicta that it may be waived by failure to object to offending evidence and Minnesota’s Supreme Court has held that the right is not one that requires an affirmative waiver in writing or on the record. Thus, case law did not make clear to the district court that it “was plainly required to treat the confrontation right as personal because it is fundamental.” Thus, any error in admitting D.A.’s prior testimony was not plain. State v. Nelson, A23-1919, 35 N.W.3d 156 (Minn. May 20, 2026).

PREDATORY OFFENDER REGISTRATION: STATE FAILED TO PROVE APPELLANT KNOWINGLY FAILED TO REPORT HIS WORKPLACE ADDRESS AS BOTH HIS WORKPLACE AND SECONDARY ADDRESSES

Appellant was convicted of failing to register as a predatory offender after police found him staying in a restaurant where he worked and stayed overnight occasionally. Prior to his arrest, Appellant completed Change of Information and Address Verification forms with the BCA, listing a new primary address and the restaurant as his workplace. The restaurant was not listed as his secondary address on either form.

Predatory offender registration is required by Minn. Stat. § 243.166, subd. 1b(a)(1). Registration requires providing certain information, including the offender’s primary address, secondary addresses, and workplace addresses, and the information must be updated when it changes. Minn. Stat. § 243.166, subd. 4a(a) and (b). The registration statute does not expressly require an offender to present the required information in any particular format nor expressly require the offender to specify the statutory categories that apply to the provided information. The statute also does not require an offender to provide an address multiple times if the address is responsive to multiple paragraphs of section 243.166, subd. 4a(a).

The State proved that the restaurant was both Appellant’s workplace and secondary address, so he was required to provide that address in his registration. However, even if the registration statute required Appellant to specify that the restaurant was both his workplace and secondary addresses, the State failed to prove Appellant knowingly failed to do so. One reasonable hypothesis from the circumstances proved at trial is that Appellant believed he was in compliance with the registration statute when he reported the restaurant address as his employment address. Appellant twice provided the State with his workplace address and never attempted to conceal the address. Thus, the circumstantial evidence was insufficient to prove Appellant knowingly violated the registration statute. Appellant’s conviction is reversed. State v. Heggs, A25-0785, 2026 WL 1465722 (Minn. Ct. App. May 26, 2026).

DOUBLE JEOPARDY: NO VIOLATION OF DOUBLE JEOPARDY TO REINSTATE APPELLANT’S CONVICTION UPON A MOTION FOR RECONSIDERATION OF THE POSTCONVICTION COURT’S ORDER VACATING THE CONVICTION

Appellant was charged with felony domestic assault, which required proof of two or more previous domestic violence-related convictions within the prior ten years. Defense counsel stipulated to the prior convictions, in order to avoid the “highly prejudicial” prior convictions from being introduced or proven at trial. The stipulation was made on the record and the prior convictions element was omitted from the jury instructions. Appellant was found guilty and convicted. The postconviction court vacated the conviction on the grounds that the jury had not been asked to determine whether the State had proven the prior convictions element of the offense. Upon the State’s motion for reconsideration, the postconviction reinstated Appellant’s conviction and the Court of Appeals affirmed. Appellant argues the reinstatement violated his rights under the Double Jeopardy Clause.

Under the Double Jeopardy Clause, a person cannot be prosecuted or punished more than once for a single offense. Generally, review following an acquittal is not permitted. However, where a jury’s guilty verdict is set aside and judgment of acquittal is entered by the court, the State may appeal to reinstate the jury’s verdict, as there is no risk of multiple punishments or successive prosecutions, given that the remedy would be entry of conviction based on the jury’s verdict rather than a retrial.

Here, although Appellant’s conviction was reinstated following a motion for reconsideration to the district court, rather than on appeal, there was still no violation of double jeopardy. There was no risk of successive prosecution, and the district court did not impose a second punishment on Appellant.

Appellant also argues his conviction must be reversed because the State failed to prove the prior offense element of felony domestic assault. The stipulation by defense counsel was invalid, as Appellant did not personally waive his right to have the jury decide whether the element was satisfied. However, this error does not entitle Appellant to relief, as he invited the error and declining to correct the invited error will not seriously affect the fairness, integrity, or reputation of judicial proceedings. State v. Sullivan, A23-1134, 35 N.W.3d 387 (Minn. May 27, 2026).