State of Minnesota v. Kim Ronnie Blatcher, A16-69

Blatcher attended a party at J.P.'s house in February 2015.
J.P. invited M.L. to the party to purchase a gun, intending to rob him; Blatcher was aware of the plan.
Upon M.L.'s arrival, Blatcher and J.P. assaulted him and took his belongings, including cash.
M.L. suffered chipped teeth, back abrasions, mouth lacerations, and a concussion.
Blatcher was charged with aiding and abetting first-degree aggravated robbery and aiding and abetting third-degree assault, and the jury convicted on both counts.
The district court denied a downward dispositional departure and sentenced Blatcher to 48 months in prison.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Plain-error omission of instructions	State argues omission was plain error affecting rights.	Blatcher contends the omission misstates law and confuses jurors.	No reversible plain-error; omission not error.
Judicial response to jury questions	State argues court properly clarified law in response to questions.	Blatcher claims the responses were improper or confusing.	District court did not abuse discretion; responses were correct.
Downward dispositional departure denial	State argues the court acted within discretion and reasons supported denial.	Blatcher contends he was particularly amenable to probation and entitled to departure.	Affirmed; no abuse of discretion in denying departure.

State v. Gutierrez, 667 N.W.2d 426 (Minn. 2003) (jury instructions must not be confusing on fundamental law)
State v. Gatson, 801 N.W.2d 134 (Minn. 2011) (instructions are not erroneous if they fairly explain the law)
State v. Milton, 821 N.W.2d 789 (Minn. 2012) (plain-error test for trial errors)
State v. Peterson, 673 N.W.2d 482 (Minn. 2004) (omission of preliminary instructions in final charge can be reversible)
State v. Duemke, 352 N.W.2d 427 (Minn. App. 1984) (preliminary instructions on circumstantial evidence need not be repeated)
State v. Crow, 730 N.W.2d 272 (Minn. 2007) (benefitting from a crime may be evidence on elements of aiding and abetting)
State v. Murphy, 380 N.W.2d 766 (Minn. 1986) (courts may amplify or respond to jury questions in appropriate circumstances)
State v. Taylor, 869 N.W.2d 1 (Minn. 2015) (standard for evaluating whether error affects fairness)
State v. Donnay, 600 N.W.2d 471 (Minn. App. 1999) (amenability to probation as a basis for dispositional departure)
State v. Olson, 765 N.W.2d 662 (Minn. App. 2009) (district court not required to depart if not warranted)
State v. Pegel, 795 N.W.2d 251 (Minn. App. 2011) (district court must consider circumstances for and against departure)
State v. Van Ruler, 378 N.W.2d 77 (Minn. App. 1985) (no requirement to explain reasons for presumptive sentence)