State of Minnesota v. Diamond Lee Jamal Griffin, 2016 Minn. LEXIS 720

On July 8, 2013, Griffin and an accomplice (Grant) armed with a .22 semiautomatic pistol entered the backyard of Francisco Benitez‑Hernandez during a robbery attempt; Griffin struck Benitez‑Hernandez, was grabbed, then shot him in the chest, killing him.
Police recovered spent casings at the scene; Benitez‑Hernandez’s blood was found on Griffin’s shorts and shoes but not on Grant’s clothing; police later recovered the .22 pistol with Grant’s assistance.
Grant pleaded guilty to multiple offenses and testified against Griffin in exchange for a reduced sentence. Forensics showed the pistol fired each round by pulling the trigger (i.e., not a hair‑trigger accidental fire).
Griffin was indicted on multiple counts including first‑degree felony murder; at trial the State introduced Spreigl (other‑bad‑acts) evidence of a 2008 attempted robbery over Griffin’s objection and elicited an improper prosecutorial question that was immediately struck.
The jury acquitted on aggravated robbery but convicted Griffin of first‑degree felony murder and other counts; the district court denied a mistrial motion, gave curative instructions, and sentenced Griffin to life plus consecutive terms.
On appeal Griffin challenged (1) admission of Spreigl evidence, (2) denial of mistrial after the improper question, (3) sufficiency of evidence to prove intent, and (4) several pro se claims; the court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of Spreigl evidence	State: prior act admissible for permissible purpose (identity/plan)	Griffin: State failed to articulate valid purpose; evidence was unfairly prejudicial	Even assuming error, no reasonable possibility Spreigl affected verdict (curative instruction + strong forensic evidence)
Denial of mistrial for improper question	State: prompt objection and curative instruction cured any prejudice	Griffin: prosecutor’s question (implying he killed someone) was highly prejudicial and warranted mistrial	Denial affirmed — prompt sustained objection, strong curative instruction, no answer given, and DNA evidence made prejudice unlikely
Sufficiency of evidence to prove intentional murder	State: circumstantial evidence (bringing gun, firing at victim, regaining balance then pulling trigger, close range, blood on defendant) supports intent	Griffin: shooting could have been accidental during being grabbed/falling	Evidence sufficient — reasonable inferences support intent and are inconsistent with accidental‑discharge hypothesis
Pro se claims (corroboration, Confrontation Clause, ineffective assistance, cumulative error)	Griffin: multiple procedural and constitutional errors require reversal	State: claims lack merit on the record	Court reviewed each and found none meritorious; conviction affirmed

State v. Spreigl, 272 Minn. 488, 139 N.W.2d 167 (Minn. 1965) (foundation for other‑bad‑acts evidence rule)
State v. Ness, 707 N.W.2d 676 (Minn. 2006) (plan exception requires marked similarity)
State v. Forsman, 260 N.W.2d 160 (Minn. 1977) (merged plan/identity inquiry criticized in concurrence)
State v. Bolte, 530 N.W.2d 191 (Minn. 1995) (harmless‑error test for wrongly admitted Spreigl evidence)
State v. Clark, 755 N.W.2d 241 (Minn. 2008) (jurors presumed to follow limiting instructions)
State v. McAllister, 862 N.W.2d 49 (Minn. 2015) (two‑step test for intent from circumstantial evidence)
State v. Andersen, 784 N.W.2d 320 (Minn. 2010) (framework for reviewing circumstantial evidence and inferences)
State v. Young, 710 N.W.2d 272 (Minn. 2006) (jury may infer intent from nature of killing)