State of Minnesota v. Eddie Matthew Mosley
2014 Minn. LEXIS 461
| Minn. | 2014Background
- Victims DeLois Brown and her parents Clover and James Bolden were found shot to death in Brown’s home on April 9, 2012; each victim had two close-range gunshot wounds to the head.
- Eddie Mosley, who lived in St. Louis and was a relative of Brown’s daughter W.H., was indicted on nine counts of first‑degree murder (premeditated and felony murder variants). He waived a jury and proceeded to a bench trial.
- Key prosecution evidence: M.T. (Mosley’s companion on a drive from St. Louis) placed Mosley in Brooklyn Park the morning of the murders, observed blood on Mosley, and testified about Mosley disposing of clothing, a gun, and other items; store and gas‑station surveillance corroborated movements; a daycare parent observed a hooded male on a bicycle near the house and later identified Mosley in court.
- Defense evidence: an alibi witness and cell‑phone records suggesting Mosley’s phone remained in St. Louis; defense argued others could have used Mosley’s phone and that identification was unreliable.
- Trial rulings at issue on appeal: admission of the daycare parent’s in‑court identification, exclusion of defense expert testimony on eyewitness identification, and alleged prosecutorial misconduct relating to elicited testimony and introduction of Mosley’s unredacted text messages.
- Outcome below: bench conviction on three counts of first‑degree premeditated murder; three consecutive life sentences without possibility of release. Court of Appeals: affirmed.
Issues
| Issue | Mosley’s Argument | State’s Argument | Held |
|---|---|---|---|
| Admission of in‑court eyewitness identification (due process) | Identification was product of unnecessarily suggestive circumstances and violated due process | Identification was spontaneous by the witness without law enforcement involvement; thus no due‑process violation (Perry framework) | Admission did not violate due process because identification was not arranged by law enforcement; affirmed |
| Exclusion of expert testimony on eyewitness reliability (Rule 702 / right to present a defense) | Expert testimony on memory/fallibility was necessary and would aid the trier of fact | Proffer was general, not tied to circumstances of this witness; existing safeguards (cross‑examination, argument, instructions) made expert unnecessary | District court did not abuse discretion; testimony not shown to be helpful to fact‑finder; right to present defense not violated |
| Exclusion challenge under Rule 403 to identification testimony | Identification was unreliable and unfairly prejudicial and should have been excluded | Identification was relevant to identity; reliability issues go to weight, not admissibility; Rule 403 disfavors exclusion | Forfeited issue (no Rule 403 objection); on plain‑error review court found no abuse of discretion in admitting testimony |
| Prosecutorial misconduct (eliciting character/inflammatory evidence; unredacted texts) | Prosecutor elicited irrelevant and prejudicial testimony (drug references, domestic/sexual living arrangements, graphic texts) that violated rules and warranted new trial | Testimony was limited and relevant (rebutted alibi, showed motive via deleted texts); even if plain error, overwhelming evidence of guilt and no substantial rights affected | Modified plain‑error review: even assuming some elicited matters were improper, errors did not affect substantial rights given strength of evidence and limited use; affirmed |
Key Cases Cited
- Perry v. New Hampshire, 132 S. Ct. 716 (2012) (due‑process rule applies only when law enforcement arranges unnecessarily suggestive identification)
- State v. Ostrem, 535 N.W.2d 916 (Minn. 1995) (five‑factor reliability test for suggestive identifications)
- State v. Miles, 585 N.W.2d 368 (Minn. 1998) (upholding district court discretion to exclude eyewitness‑identification expert where safeguards existed)
- State v. Helterbridle, 301 N.W.2d 545 (Minn. 1980) (court may exclude expert testimony on eyewitness identification; other safeguards can mitigate risk of wrongful conviction)
- United States v. Olano, 507 U.S. 725 (1993) (standard for plain‑error review of forfeited objections)
- State v. Griller, 583 N.W.2d 736 (Minn. 1998) (appellate review standards for discretionary trial rulings)