State of Minnesota v. Josue Robles Fraga
2015 Minn. LEXIS 234
| Minn. | 2015Background
- Defendant Josue Robles Fraga was tried twice for the 2008 death of his 2-year-old niece; after conviction in the first trial, the district court granted a new trial based on newly disclosed evidence (Child A later admitting sexual contact with the victim).
- At the retrial Fraga was indicted on five murder counts and convicted; he appealed raising multiple errors including juror bias, venue, evidentiary rulings, witness-preclusion, and multiple convictions.
- During voir dire at the retrial two jurors knew the first trial ended in conviction; one juror ("Juror M") had read news accounts, discussed the case with family (including a hospital nurse relative), expressed discomfort and equivocal willingness to be impartial, and knew some witnesses.
- Defense exhausted peremptory challenges and moved to strike Juror M for cause; the district court denied the challenge and seated Juror M.
- The Supreme Court held that seating a juror who was actually biased and not rehabilitated is structural error requiring reversal and remand for a new trial, but refused to adopt a rule that mere knowledge of a prior conviction is automatic implied bias.
- The Court also clarified evidentiary rule adoption for Minn. Stat. §634.20 (admitting domestic-conduct evidence against family/household members) and discussed (without final ruling for retrial) admission of a newspaper article and other issues for judicial economy.
Issues
| Issue | Fraga's Argument | State's Argument | Held |
|---|---|---|---|
| Whether a juror who knows a prior trial ended in conviction is impliedly biased | A juror who knows of a prior conviction in a retrial is automatically disqualified (implied bias) | Knowledge of a prior conviction does not create implied bias absent other factors; Rule 26.02 is exclusive | Rejected implied-bias extension; Rule 26.02 supplies exclusive grounds; knowledge alone not implied bias |
| Whether seating Juror M (who expressed equivocal impartiality and discussed the case with relatives) was reversible error | Juror M’s statements and equivocation showed actual bias; not rehabilitated; reversal required | Juror M said he could base decision on courtroom evidence and was adequately rehabilitated; no showing of actual prejudice required | Reversed: Juror M exhibited actual bias, was not unequivocally rehabilitated, and his seating is structural error requiring automatic reversal |
| Admission of a newspaper article referring to the prior trial and alternative perpetrator | Article admission was unfairly prejudicial under Rule 403 and risked contaminating the jury | Article had limited relevance and probative value; could be managed by redaction/instructions | Court left the matter open for retrial: cautioned district court to weigh probative value, hearsay issues, redactions, and limiting instructions if offered |
| Admissibility under Minn. Stat. §634.20 of evidence of defendant's alleged sexual abuse of a relative | Such evidence was improper or prejudicial when used to prove propensity | §634.20 allows admission of domestic-conduct evidence against family/household members subject to balancing (probative v. unfair prejudice) | Court adopts §634.20 as a rule of evidence to permit evidence of domestic conduct against other family/household members, but its admission depends on context and balancing |
Key Cases Cited
- Williams v. State, 764 N.W.2d 21 (Minn. 2009) (discussing limits of implied-bias doctrine)
- Brown v. State, 732 N.W.2d 625 (Minn. 2007) (describing implied bias and noting extreme cases)
- Leonard v. United States, 378 U.S. 544 (1964) (trial court error where second-panel heard first verdict announced)
- Stufflebean v. State, 329 N.W.2d 314 (Minn. 1983) (holding Rule 26.02 provides exclusive grounds to challenge for implied bias)
- Logan v. State, 535 N.W.2d 320 (Minn. 1995) (biased juror is structural error requiring reversal)
- Munt v. State, 831 N.W.2d 569 (Minn. 2013) (deference to district court on juror-bias factual findings; standard of review)
- Prtine v. State, 784 N.W.2d 303 (Minn. 2010) (rehabilitation standard: juror must state unequivocally they will set aside preconceived notions)
- McCoy v. State, 682 N.W.2d 153 (Minn. 2004) (adopting §634.20 as rule of evidence for victim-similar-conduct evidence)
- State v. Moore, 846 N.W.2d 83 (Minn. 2014) (interpreting scope of evidence admissible under §634.20)