State of Minnesota v. Maureen Ndidiamaka Onyelobi, 879 N.W.2d 334

Background

Victim Anthony Fairbanks was murdered on March 8, 2014; surveillance and witness accounts placed a two-tone van (registered to Onyelobi) at the scene shortly after three gunshots.
A phone number (the “208” number) used to arrange heroin purchases was linked to a white Samsung phone recovered from Onyelobi’s hotel room; cell-tower data placed calls from that number near the murder site.
Police, investigating Fairbanks’s murder and recent heroin distribution, entered a hotel room occupied by David Johnson (and later entered under a warrant), saw suspected narcotics in plain view, and arrested Onyelobi after she arrived at the hotel.
A storage unit rented by Onyelobi yielded a safe containing a loaded handgun; ballistics tied that handgun to casings at the murder scene; latent prints and DNA on the gun implicated Johnson and did not exclude Onyelobi.
At trial Onyelobi was convicted of first-degree premeditated murder under Minnesota’s aiding-and-abetting (accomplice-liability) statute and sentenced to life without release. On appeal she challenged (1) probable cause for arrest/suppression, (2) Batson peremptory-strike rulings, (3) accomplice-liability jury instructions, and (4) several evidentiary/closing-argument matters.

Issues

Issue	Onyelobi's Argument	State's Argument	Held
Probable cause for arrest and admissibility of evidence seized after arrest	Arrest lacked probable cause because Johnson alone was in the hotel room when drugs were observed and linkage to the murder was only a phone number; suppression required	Collective police knowledge (208 phone, hotel registration, van in lot, S.F.’s ID) supported probable cause for constructive possession and for arrest; fruits admissible	Probable cause existed for possession arrest; suppression denial affirmed
Batson challenges to State’s peremptory strikes (jurors R.D., M.B., N.F.)	Strikes were racially motivated; State’s race-neutral reasons were pretextual given disparate impact and comparative questioning	State gave race-neutral reasons (criminal history/family contacts; belief police lied/wrongful conviction; inability to view evidence/be fair); court observed credibility and panel context	Trial court did not clearly err in rejecting Batson claims; strikes upheld
Jury instruction on accomplice liability (scope of intent)	Instruction allowed conviction as accomplice for first-degree murder even if defendant intended to aid only a lesser crime; Rosemond requires advance knowledge of the specific offense	Instruction tracked Minnesota statute and tied aiding-and-abetting to the charged murder; prosecutor did not argue post hoc knowledge; Minnesota precedent controls	Instruction not erroneous or misleading under Minnesota law; Rosemond distinction not applicable here
Failure to include efficacy or specify "intended crime" in expansive-liability instruction	Court should have required showing that defendant’s aid/presence actually furthered the crime and should have specified the original intended offense	Those points were foreclosed by Minnesota precedent (State v. Taylor); defendant did not preserve objections so review is for plain error	No plain error; instructions consistent with Taylor; affirming conviction

Key Cases Cited

Batson v. Kentucky, 476 U.S. 79 (prohibiting race-based peremptory strikes under the Fourteenth Amendment)
Rosemond v. United States, 134 S. Ct. 1240 (2014) (defendant aiding armed drug crime needed advance knowledge of firearm presence; discussed but distinguished)
State v. Taylor, 869 N.W.2d 1 (Minn. 2015) (Minnesota precedent on accomplice liability, efficacy, and expansive-liability instructions)
State v. Diggins, 836 N.W.2d 349 (Minn. 2013) (describing three-step Batson framework adopted in Minnesota)
State v. Ortega, 770 N.W.2d 145 (Minn. 2009) (constructive possession standards and probable-cause principles)
Purkett v. Elem, 514 U.S. 765 (1995) (race-neutral explanation need not be persuasive or plausible)