State of Minnesota v. Jonas David Nelson, 2016 Minn. LEXIS 664

In January 2014, 18-year-old Jonas David Nelson called 911 and reported his father had been shot; officers found the father dead from a gunshot to the head.
Nelson gave an on-scene statement to law enforcement in an unmarked car after officers discussed the forensic evidence they planned to run; he waived Miranda and later confessed he shot his father while he slept.
Two additional recorded confessions followed after arrest and at the jail; Nelson moved to suppress the statements as involuntary.
Defense expert testified Nelson was socially and psychologically immature, fatigued, and conditioned to acquiesce to male authority; the State’s expert disagreed.
The district court denied suppression; a jury convicted Nelson of first-degree premeditated murder (and two lesser-included offenses), and the court sentenced him to life without parole under Minnesota’s heinous-crimes statute.
On appeal, Nelson challenged (1) voluntariness of his confessions, (2) the constitutionality of a mandatory life-without-parole sentence given his youth (raising Miller v. Alabama), and (3) two lesser-included convictions listed on the warrant order.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Nelson's confessions were voluntary	Nelson: on-scene tactics (sympathy, appeals to honesty), fatigue, immaturity, and conditioning to obey male authority overbore his will	State: officers gave Miranda, used noncoercive motivational statements, forensic confrontation prompted change in story, Nelson understood consequences and denied coercion	Confessions voluntary under totality of circumstances; suppression denial affirmed
Whether mandatory life-without-parole violates Eighth Amendment given Nelson's psychological youth	Nelson: though legally 18, he was psychologically/socially juvenile, so Miller requires individualized sentencing	State: (procedural) claim forfeited because not raised in district court	Forfeited on appeal; court did not reach merits of Miller claim
Whether convictions for lesser-included offenses may stand alongside first-degree conviction	Nelson: order lists convictions for second-degree intentional and felony murder despite conviction/sentence only for first-degree murder	State: acknowledged lesser-included convictions should not stand in addition to the greater offense	Vacated the two lesser-included convictions on the warrant order

Dickerson v. United States, 530 U.S. 428 (confession admissibility governed by voluntariness and Miranda framework)
Colorado v. Connelly, 479 U.S. 157 (some coercive state action required to render confession involuntary)
Lynumn v. Illinois, 372 U.S. 528 (test for whether will was overborne in confession cases)
Wong Sun v. United States, 371 U.S. 471 (fruit-of-the-poisonous-tree principle for statements)
State v. Zabawa, 787 N.W.2d 177 (Minn. standard for voluntariness; totality of circumstances review)
State v. Pilcher, 472 N.W.2d 327 (sympathetic interrogation approach not dispositive of coercion)
State v. Clark, 738 N.W.2d 316 (distinguishing inducements from appeals to conscience)
Miller v. Alabama, 567 U.S. 460 (mandatory life without parole for juveniles implicates Eighth Amendment)