State of Minnesota v. Keith Richard Rossberg
2014 Minn. LEXIS 362
Minn.2014Background
- Rossberg was convicted of first‑degree premeditated murder of Devan Hawkinson and appeals alleging improper admission of Spreigl and relationship evidence and hearsay, plus Confrontation Clause concerns.
- The district court admitted Spreigl evidence, including a 2008 911 call about a possible suicide and Rossberg’s possession of a weapon, with limiting instructions.
- The district court also admitted extensive testimony about Rossberg’s long, volatile relationship with Hawkinson and D.T., including alleged threats, confrontations, and a so‑called love triangle.
- From 2008 to 2010, Rossberg repeatedly confronted Hawkinson at Hawkinson’s trailer, resulting in injuries to Hawkinson and police involvement.
- Evidence at trial included a disappeared .22 pistol shortly before the murder, shell casings at the scene matching the gun found in Rossberg’s trailer, and handwritten notes and a threatening letter.
- The Supreme Court affirmed, deeming any evidentiary errors harmless and rejecting Rossberg’s pro se claims.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of Spreigl evidence without a precise fact identified | Rossberg | State | Error, but harmless. |
| Relevance of 2008–2010 relationship evidence given the time gap | Rossberg | State | Evidence relevant; not reversible. |
| Confrontation Clause impact of Hawkinson’s statements to police | Rossberg | State | No substantial rights violation; harmless. |
| Pro se claims merit in light of record | Rossberg | State | No relief warranted. |
Key Cases Cited
- State v. Spreigl, 272 Minn. 488 (Minn. 1965) (established framework for 404(b) evidence)
- Angus v. State, 695 N.W.2d 109 (Minn. 2005) (precise disputed facts required for Spreigl admission)
- State v. McCoy, 682 N.W.2d 153 (Minn. 2004) (distinguishes collateral versus relationship evidence)
- State v. Washington, 693 N.W.2d 195 (Minn. 2005) (balancing of pre-offense conduct timing and relevance)
- State v. Fardan, 773 N.W.2d 303 (Minn. 2009) (plain-error review of evidentiary error)
- State v. Ness, 707 N.W.2d 676 (Minn. 2006) (harmless error standard for evidentiary claims)
- State v. Goelz, 743 N.W.2d 249 (Minn. 2007) (importance of substantial rights in plain error)
- State v. Griller, 583 N.W.2d 736 (Minn. 1998) (standard for reviewing plain errors)
- State v. Brown, 792 N.W.2d 815 (Minn. 2011) (confrontation clause sequencing and preservation)
- State v. DeRosier, 695 N.W.2d 97 (Minn. 2005) (victim’s state of mind usually not relevant absent defense)