State of Minnesota, Respondent, vs. Mohamed Abdulgani Ahmed, Appellant, A240037

Ahmed was convicted of first-degree controlled substance conspiracy, first-degree controlled substance sale, and second-degree controlled substance possession arising from fentanyl sales in an East Grand Forks apartment. 1
Police found Ahmed’s wallet, cash, and a bag containing 775 fentanyl pills in a bedroom closet, and later analysis suggested the pills weighed about 77.5 grams. 2
Ahmed admitted selling fentanyl to one person and others, but denied knowing about the 775-pill bag and said it belonged to his roommate A.F. 3
At trial, the prosecutor argued the State did not need to prove Ahmed knew the conspiracy involved more than fifty grams of fentanyl. 4
The jury found Ahmed guilty on all counts, and the court of appeals largely affirmed before this court granted review. 5
The supreme court held the prosecutor’s closing misstatement was plain error that prejudiced Ahmed and required a new trial on the challenged convictions. 6
The court reversed in part, vacated in part, and remanded for a new trial on conspiracy, sale, and possession counts. 7

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did prosecutor misstate conspiracy law in closing? 8	Ahmed said the State had to prove he knew the conspiracy involved 50 grams.	State said knowledge of the exact weight was unnecessary.	Yes; the statement misstated Minnesota conspiracy law. 9
Was the error plain? 10	Ahmed argued the error was clear under Kuhnau.	State claimed Aviles-Alvarez made the law unclear.	Yes; controlling precedent made the error plain. 11
Did the error affect substantial rights? 12	Ahmed argued the misstatement likely affected the verdicts.	State said evidence was strong and the misstatement was brief.	Yes; prejudice was shown. 13
Is reversal needed to protect fairness and integrity? 14	Ahmed sought reversal because the jury may have ignored an element.	State argued any error was harmless.	Yes; new trial required. 15

State v. Kuhnau, 622 N.W.2d 552 (Minn. 2001) (controlled substance conspiracy requires intent to commit every element of the underlying offense 16)
State v. Thompson, 3 N.W.3d 257 (Minn. 2024) (describes Minnesota’s modified plain-error test 17)
State v. Portillo, 998 N.W.2d 242 (Minn. 2023) (plain-error framework and prejudice standard 18)
State v. Segura, 2 N.W.3d 142 (Minn. 2024) (prosecutors err when they misstate the law in closing argument 19)
State v. Atkins, 543 N.W.2d 642 (Minn. 1996) (reasonable foreseeability under accomplice liability is a jury question 20)
State v. McAllister, 862 N.W.2d 49 (Minn. 2015) (reasonable foreseeability is objective and judged from the defendant’s position 21)
State v. Watkins, 840 N.W.2d 21 (Minn. 2013) (omitting an element can affect substantial rights and require reversal 22)
State v. Hallmark, 927 N.W.2d 281 (Minn. 2019) (a vacated conviction’s underlying verdict remains in force 23)
State v. Ezeka, 946 N.W.2d 393 (Minn. 2020) (general rule that defendants are liable only for crimes they personally commit 24)
State v. Ramey, 721 N.W.2d 294 (Minn. 2006) (prosecutorial-error cases focus on whether the defendant received a fair trial 25)