State of Minnesota v. Gregory Antoine Davis, 864 N.W.2d 171

Jones was killed December 22, 2011 in a Minneapolis duplex; Davis was Jones’s boyfriend A.M.’s partner and the murder suspect.
Jones’s belongings were stolen; Davis’s involvement was alleged through burglary as the predicate for felony murder.
Davis’s statements and later trial involved an alternative-perpetrator theory naming D.M. (Jones’s boyfriend) as the true killer.
District court allowed some reverse-Spreigl evidence and excluded other acts; hearsay was discussed.
Davis attended trial intermittently; court warned about presence and proceeded without Davis after voluntary absences.
Davis was convicted of first-degree felony murder and unlawful firearm possession, then appealed on four grounds.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the burglary instruction misstated the intent to steal element	State argues error in burglary element	Davis argues failure to define theft, and misstatement of intent	No reversible plain error; evidence did not affect substantial rights.
Whether the court impermissibly directed jury on order of considering charges	State contends no improper guidance	Davis argues instruction suggested order to consider lesser offenses	Not plain error; no reversible impact.
Whether exclusion of reverse-Spreigl evidence was proper	State argues relevance and admissibility standards were met	Davis contends evidence supports alternative-perpetrator defense	District court did not abuse discretion; acts not sufficiently similar or trustworthy.
Whether proceeding without Davis present violated Minn. R. Crim. P. 26.03	State contends rule allows trial in absence for justified failure to attend	Davis argues presence required; waiver ineffective	Trial valid; present absence was a voluntary waiver and proper under rule 26.03.

State v. Griller, 583 N.W.2d 740 (Minn. 1998) (plain-error review framework; three-pronged analysis; substantial rights)
State v. Kelley, 855 N.W.2d 269 (Minn. 2014) (standard for correcting errors in trial)
State v. LaForge, 347 N.W.2d 247 (Minn. 1984) (forfeiture vs. plain-error review for jury instructions)
State v. Vang, 847 N.W.2d 248 (Minn. 2014) (jury instruction adequacy and law definition concerns)
State v. Pendleton, 567 N.W.2d 265 (Minn. 1997) (instructional accuracy; legal definitions in jury charges)
State v. Swaney, 787 N.W.2d 541 (Minn. 2010) (reverse- Spreigl evidence; similarity and relevance)
State v. Jones, 678 N.W.2d 1 (Minn. 2004) (reverse- Spreigl evidentiary rules)
State v. Scanlon, 719 N.W.2d 674 (Minn. 2006) (reliance on procedural rules for evidentiary decisions)
State v. Blom, 682 N.W.2d 578 (Minn. 2004) (evidentiary rulings; historical context of Spreigl)
State v. Lanam, 459 N.W.2d 656 (Minn. 1990) (circumstances surrounding hearsay reliability)