Darek Jon Nelson v. State of Minnesota
2016 Minn. LEXIS 345
| Minn. | 2016Background
- On Jan. 13, 2012, Darek Jon Nelson stabbed co-worker Vinessa Lozano multiple times at Pizza Ranch; she died and Nelson was arrested at the scene with a knife.
- Nelson confessed in a custodial interview that he brought a knife to work, had thought about stabbing Lozano for days, followed her, and continued stabbing even after intervention and as police arrived.
- Rule 20 evaluations diagnosed Nelson with Asperger’s Disorder and noted significant social impairment and naivety about the criminal system, but found he could consult with counsel and did not meet criteria for a mental‑illness defense.
- Nelson pleaded guilty to first‑degree premeditated murder on Jan. 18, 2013, after a plea colloquy in which he admitted facts supporting intent and premeditation following a bench conference and private consultation with counsel.
- He was sentenced to life without release. Nearly two years later he filed a postconviction petition to withdraw his plea claiming it was not intelligent, accurate, or voluntary; the postconviction court denied relief after an evidentiary hearing.
- The Minnesota Supreme Court affirmed, holding Nelson failed to meet his burden that the plea was invalid.
Issues
| Issue | Plaintiff's Argument (Nelson) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Whether plea was intelligently entered (understood charges, rights, consequences) | Nelson asserted he was naïve due to Asperger’s and did not adequately understand or was pressured to answer to secure the plea | Court and counsel explained rights, consequences; Nelson acknowledged understanding multiple times and signed plea petition | Court held plea was intelligent: record shows Nelson understood charges, rights, and life sentence consequence |
| Whether plea was accurate (adequate factual basis for first‑degree premeditated murder) | Nelson claimed statements during colloquy negated intent and premeditation and court failed to rehabilitate the factual basis | State pointed to Nelson’s admissions (bringing knife, planning, following, continuing to stab despite intervention) and other record evidence supporting intent/premeditation | Court held factual basis adequate: credible evidence and reasonable inferences support intent and premeditation |
| Whether use of leading questions invalidated the plea | Nelson argued the court’s leading questions undermined a proper factual basis | State noted court initially used open questions; limited leading questions do not automatically invalidate plea where record supports conviction | Court held limited leading questions did not invalidate plea given solid factual record |
| Whether plea was voluntary (coercion/pressure) | Nelson claimed counsel told him to answer “yes” and he felt pressured/naïve to sign | State relied on counsel’s testimony that Nelson chose to plead, was not coerced, and had opportunity to confer and decline | Court held plea voluntary: petitioner failed to show coercion and record showed voluntariness |
Key Cases Cited
- Raleigh v. State, 778 N.W.2d 90 (Minn. 2010) (standards for accuracy, voluntariness, intelligence of plea)
- Riley v. State, 819 N.W.2d 162 (Minn. 2012) (postconviction factual findings review and burden to show plea invalid)
- Iverson v. State, 664 N.W.2d 346 (Minn. 2003) (statements negating essential elements can render factual basis inadequate)
- Lussier v. State, 821 N.W.2d 581 (Minn. 2012) (caution against exclusively leading questions during plea)
- Al‑Naseer v. State, 788 N.W.2d 469 (Minn. 2010) (standard for factual basis and reasonable inferences)
- Neumann v. State, 262 N.W.2d 426 (Minn. 1978) (trial judge must ensure facts exist from which guilt can be reasonably inferred)
- Moore v. State, 481 N.W.2d 355 (Minn. 1992) (discussion of factual‑basis standards)
- Raymond v. State, 440 N.W.2d 425 (Minn. 1989) (intent may be inferred from nature/extent of wounds and failure to aid victim)