State of Minnesota v. Claude Monroe Washington
A15-1757
| Minn. Ct. App. | Aug 22, 2016Background
- Claude Washington was charged with possession of a firearm by an ineligible person after police executed a May 6, 2014 search of his Minneapolis home and found a loaded Ruger handgun under a dresser in an adult bedroom.
- Evidence tying Washington to the room and gun: mail and medical papers bearing his name in the bedroom, about 200 rounds of ammunition elsewhere in the house that fit the gun, and a latent fingerprint from the handgun matching Washington at 15 points.
- DNA testing of the gun and magazine produced mixed samples that did not exclude Washington; trial testimony explained identical twins share DNA but not fingerprints.
- Washington stipulated he was ineligible to possess firearms; his twin brother (also living at the address) was advanced as an alternate possessor at trial.
- The district court omitted a statutory definition of “firearm” from jury instructions but told jurors to apply common, ordinary meanings; Washington did not object at trial and was convicted by a jury and sentenced to the mandatory minimum.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether failure to instruct jury on definition of “firearm” was error requiring reversal | State: omission was harmless because the gun was undisputedly a firearm at trial | Washington: court plainly erred by not defining "firearm," which is an element, and that could prejudice him | Court: omission was plain error but not prejudicial; no reversal |
| Whether evidence was sufficient to prove constructive possession | State: circumstantial evidence (ownership, location, mail, ammo, fingerprint, DNA) supports constructive possession | Washington: twin could have placed the gun; proffered alternate hypothesis | Court: evidence sufficient; alternate hypothesis unreasonable given fingerprint and other facts |
Key Cases Cited
- State v. Milton, 821 N.W.2d 789 (Minn. 2012) (plain-error review standard for unobjected-to jury instructions)
- State v. Kjeseth, 828 N.W.2d 480 (Minn. App. 2013) (jury must be instructed on elements of the charged crime)
- State v. Fleming, 724 N.W.2d 537 (Minn. App. 2006) (air- or gas-powered BB gun qualifies as a firearm under Minn. Stat. § 624.713)
- State v. Salyers, 858 N.W.2d 156 (Minn. 2015) (constructive-possession principles and tests in firearm cases)
- State v. Silvernail, 831 N.W.2d 594 (Minn. 2013) (two-step test for reviewing convictions based on circumstantial evidence)