Hawes v. State
2013 Minn. LEXIS 113
| Minn. | 2013Background
- Hawes was convicted of aiding and abetting first-degree premeditated murder and obstructing an investigation; life imprisonment without parole.
- Direct and postconviction appeals consolidated; Hawes challenged ineffective assistance of trial counsel and Confrontation Clause errors.
- Edwin Hawes disappeared Oct 29, 2008; his body was found burned two days later on Hawes’ farm property.
- State’s theory: Hawes, his sister Elizabeth, his girlfriend Dorniden, and brother-in-law Romig planned and executed Edwin’s murder and attempted cover-up.
- Evidence showed planning and motive: weapons prepared, gloves with Edwin/Hawes DNA, crossbow, bleach, stolen Passat, and efforts to retrieve the car while avoiding law enforcement.
- Postconviction court found substantial planning/motive evidence; record supported premeditation; but concluded Hawes’ ineffectiveness claim failed and Confrontation Clause issue was harmless error; appellate court affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Ineffective assistance of counsel standard | Hawes argues errors affected trial outcome | Hawes asserts counsel’s failures met Strickland prongs | No reasonable probability of different outcome; relief denied |
| Confrontation Clause error from out-of-court statements | Hawes claims statements were improperly admitted as unconfronted evidence | State argues statements were harmless or admissible as non-testimonial | Harmless beyond a reasonable doubt; verdict not attributable to error |
Key Cases Cited
- Strickland v. Washington, 466 U.S. 668 (Supreme Court 1984) (establishes two-prong test for ineffective assistance of counsel)
- Rhodes, 657 N.W.2d 823 (Minn.2003) (de novo review; may deny one prong if other resolves the issue)
- Moua, 678 N.W.2d 29 (Minn.2004) (premeditation evidenced by planning and motive evidence)
- Moore, 481 N.W.2d 355 (Minn.1992) (planning/means evidence supports premeditation inquiry)
- Alton, 432 N.W.2d 754 (Minn.1988) (evidence of waiting for victim supports premeditation)
- Kendell, 723 N.W.2d 597 (Minn.2006) (post-killing conduct relevant to premeditation analysis)
- Courtney, 696 N.W.2d 73 (Minn.2005) (harmless-error analysis for Confrontation Clause violations)
- Wright, 726 N.W.2d 464 (Minn.2007) (harmlessness depends on record, persuading strength of remaining evidence)
- Caulfield, 722 N.W.2d 304 (Minn.2006) (Confrontation Clause violation reviewed de novo with harmless-error standard)