Maurice Anderson v. John King
2013 U.S. App. LEXIS 20303
8th Cir.2013Background
- Anderson shot in a crowded St. Paul bar, killing Roland and injuring two bystanders Motley and Shuler.
- Amended complaint charged murder and attempted murder; original charges included bystander assaults as lesser offenses.
- Trial focused on self-defense; the State withdrew some charges and the court instructed on certain lesser-included offenses.
- Defense opted not to pursue lesser-included assault instructions; defense relied on self-defense to all charges.
- Jury convicted on four bystander assaults and second-degree felony murder; concurrent sentences totaled 332 months.
- State and federal post-trial proceedings followed, culminating in a habeas petition challenging notice/defense rights and trial instructions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the bystander assault instruction structural error? | Anderson argues it was structural, not subject to harmless error review. | State argues error was subject to harmless-error analysis and defaulted in state court pursuit of federal theory. | No structural-error federal claim; defaulted, and harmless-error review applied. |
| Did the amended instruction prejudice Anderson's ability to defend? | Anderson contends late addition deprived notice and defense. | State maintains no prejudice; Anderson relied on self-defense for all charges and had notice initially. | No substantial prejudice; defense strategy remained centered on self-defense. |
Key Cases Cited
- Schmuck v. United States, 489 U.S. 705 (Supreme Court (1989)) (structural vs. nonstructural error distinctions)
- Gisege, 561 N.W.2d 152 (Minn. 1997) (harmless-error standard adopted by Minnesota Supreme Court)
- Washington v. Texas, 388 U.S. 14 (Supreme Court (1967)) (right to present a defense; notice and defense considerations)
- Neder v. United States, 527 U.S. 1 (Supreme Court (1999)) (defining harmless-error framework)
- Dunn v. United States, 442 U.S. 100 (Supreme Court (1979)) (structural error doctrine and applicability)
- Williams v. Taylor, 529 U.S. 362 (Supreme Court (2000)) (clearly established federal law refers to holdings, not dicta)
- Jackson v. Norris, 573 F.3d 856 (8th Cir. 2010) (record-based review of prejudice in habeas cases)