State of Minnesota v. Kong Pheng Vue, A16-286

On June 11, 2015, J.W.’s parked Jeep (with key left inside) was stolen from his Shoreview driveway; he saw an Asian man get in and drive away.
Deputies later encountered an Asian man (long hair, glasses) near a neighbor’s yard; he discarded a backpack and was detained.
The backpack contained a .380 handgun wrapped in a shirt and mail/cellphone bill bearing the name Kong Pheng Vue; a shoulder bag had a Wisconsin ID for Vue.
Vue was charged with possession of a firearm by an ineligible person and motor-vehicle theft; he stipulated to ineligibility but denied stealing the Jeep and possessing the gun.
At trial the court allowed impeachment with two unspecified 2010 Wisconsin felony drug convictions; Vue testified and was convicted on both counts.
On appeal Vue challenged (1) admission of prior convictions (Jones-factor analysis) and (2) the absence/formulation of limiting jury instructions regarding impeachment evidence.

Issue	State's Argument	Vue's Argument	Held
Admissibility of prior felony convictions for impeachment under Jones factors	Prior drug felonies are probative of credibility; factors weigh for admission	Drug convictions do not directly relate to truthfulness and the court failed to adequately record Jones analysis	Admission was proper: all Jones factors weighed in favor; any record shortcoming was harmless
Jury instruction on use of impeachment evidence (sua sponte limiting instruction and final cautionary language)	No sua sponte limiting instruction required; final instruction was adequate given context and evidence strength	Court should have given a contemporaneous limiting instruction and final instruction’s language was misleading because convictions were unspecified	No plain error: failure to give sua sponte limiting instruction not reversible; wording flaw did not affect substantial rights given strong evidence

State v. Hill, 801 N.W.2d 646 (Minn. 2011) (any felony conviction is probative of witness credibility)
State v. Swanson, 707 N.W.2d 645 (Minn. 2006) (trial court should analyze Jones factors on the record)
State v. Jones, 271 N.W.2d 534 (Minn. 1978) (sets five-factor test for admitting prior-conviction impeachment)
State v. Bettin, 295 N.W.2d 542 (Minn. 1980) (similarity of prior conviction to charged crime increases prejudice concern)
State v. Taylor, 869 N.W.2d 1 (Minn. 2015) (no plain error for not giving limiting instruction sua sponte when impeaching convictions are admitted)
State v. Kuhlmann, 806 N.W.2d 844 (Minn. 2011) (explains plain-error standard for unobjected-to trial rulings)