Supreme Court Digest: Aug. 28, 2019.

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Criminal

Evidence

Cell-Site Location

Appellant appealed his convictions for first-degree murder and attempted first-degree murder. Appellant argued that the District Court admitted evidence in violation of the Fourth Amendment, Minn. Stat. 626A.42, and Minn. R. Evid. 702. Appellant also argued that the District Court erred when it overruled his Batson challenge. Finally, he raised claims of ineffective assistance of counsel and prosecutorial misconduct in his pro se supplemental brief.

The Supreme Court held that (1) the state obtained the cell-site location information (CSLI) evidence consistent with the Fourth Amendment and the substantive requirements of Minn. Stat. 626A.42; (2) CSLI evidence does not involve a novel theory of science, and even if expert testimony regarding Gladiator Autonomous Receiver drive-test evidence involves a novel theory of science that is not generally accepted in the relevant scientific community, admission of the expert testimony was harmless under the circumstances of this case; (3) the District Court did not clearly err when it determined that appellant...