State of Minnesota v. Justin Louis Hudak, a230468

In August 2021, Justin Louis Hudak drove S.S. to a gas station in St. Cloud, Minnesota.
Hudak and N.J. had a verbal altercation inside the gas station; Hudak then told S.S. about it upon returning to the car.
Knowing S.S. had a gun, Hudak drove at S.S.'s direction, stopped near N.J., and S.S. fired multiple shots at N.J., striking him twice.
Hudak sped away from the scene with S.S. and later assisted law enforcement in locating the gun.
Hudak was convicted by a jury for aiding and abetting second-degree assault and a drive-by shooting, and he appealed the conviction, alleging insufficient evidence regarding his intent.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for aiding/abetting	Hudak did not knowingly or intentionally aid S.S.	The state presented circumstantial evidence proving intent/knowledge	Sufficient evidence supported conviction
Requirement of direct evidence of intent	Circumstantial evidence insufficient to prove required intent	Circumstantial evidence of actions and knowledge was enough	Circumstantial evidence was sufficient
Alternative innocent inferences	Hudak believed S.S. was just offering protection or bravado	Circumstances exclude reasonable inference other than guilt	Alternative inferences not reasonable
Proper application of standard of review	Immaterial facts should be considered	Only facts consistent with the verdict should be considered	Review standard upholds the verdict

State v. Milton, 821 N.W.2d 789 (Minn. 2012) (sets elements for aiding and abetting liability)
State v. Griffin, 887 N.W.2d 257 (Minn. 2016) (standards for sufficiency-of-the-evidence review)
State v. Silvernail, 831 N.W.2d 594 (Minn. 2013) (scrutiny for circumstantial evidence cases)
State v. Al-Naseer, 788 N.W.2d 469 (Minn. 2010) (circumstantial evidence must exclude reasonable hypothesis of innocence)
State v. Bahtuoh, 840 N.W.2d 804 (Minn. 2013) (jury may infer intent from conduct and circumstances)