Monday, September 18, 2017

From Russia, with love, till death do us part!

2016-M-323         Joel Marvin Munt, Appellant, vs. State of Minnesota, Respondent.

THE BACKGROUND:  Munt met Svetlana through a Russian internet dating service and married her on their second meeting.  They returned to Mankato and had three children.  They separated in 2006 and child custody shifted repeatedly over several years.

On March 28, 2010, Svetlana awaited a scheduled child visitation from Munt as she sat in her car with her children in her car in a park.  Munt drove up, pinned her car to a tree, shot her to death, and kidnapped his children.

After a bifurcated jury trial, the district court then convicted Munt of first-degree premeditated murder and imposed a life sentence without the possibility of release.

In 2013, the Supreme Court rejected Munt’s direct appeal by a 4-3 margin.  That appeal focused on the trial judge’s refusal to remove a potential juror who expressed initial reluctance about a presumption in favor of a defendant who asserted an insanity defense. The Majority held that, upon further inquiries by the prosecutor, the potential juror had been rehabilitated.

THIS DECISION:  Here, on Munt’s first post-conviction appeal, the Supreme Court rejected Munt’s two claims as untimely and meritless.

First, because appellant failed to raise jury-instruction claims that he knew or should have known about at the time of direct appeal, and no exceptions to the Knaffla bar apply, the post-conviction court did not abuse its discretion in summarily denying relief on those claims.

Second, because the holding in Miller v. Alabama is expressly limited to juveniles, and appellant was an adult when he was charged, convicted, and sentenced, the post-conviction court did not abuse its discretion in summarily rejecting appellant's claim that his sentence was unconstitutional under Miller.

Gildea (Anderson, Dietzen, Stras, Lillehaug, and Hudson)
Took No Part:  Chutich.
[CRIME] [MURDER] [PREMEDITATED] [FIRST-DEGREE] [DOMESTIC] [KIDNAP] [GILDEA]
Date: June 15, 2016

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