State of Minnesota v. Michael Bruce Rostie, A15-986

Officers served papers and observed possible drug impairment; trash search revealed meth-related items prompting a search warrant for the shared residence.
During warrant execution, officers entered the basement; someone went into the bathroom and Rostie was found standing behind the bathroom door.
Inside the bathroom officers detected fresh methamphetamine smoke, found a broken pipe with white residue, and in the bedroom (about three feet down the hall) found multiple meth-related items including a pill bottle with 12.6 g meth, pipes, scales, torches, needles, and a small vial of meth.
Garage search uncovered pseudoephedrine packages, drain cleaner, and lithium casings (precursors); Rostie’s paystub was nearby.
J.W. (Rostie’s girlfriend and co-occupant) testified she used meth, claimed ownership of many items, and said she dropped a pipe in the bathroom when startled; Rostie testified not guilty.
Jury acquitted Rostie of possession, convicted him (as principal and accomplice) of storing methamphetamine paraphernalia in the presence of a child; district court sentenced him to 18 months.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence that Rostie knowingly stored meth paraphernalia in presence of a child	The circumstantial evidence (items in shared living space, garage items near Rostie’s paystub, bathroom with fresh smoke and pipe, male-use device on torch) supports an inference Rostie knowingly stored paraphernalia	Rostie argued the items could be J.W.’s alone; circumstantial evidence does not exclude a reasonable alternative hypothesis that he was not responsible or aware	Court held circumstantial evidence, taken together, was consistent with guilt and inconsistent with any rational hypothesis except guilt; conviction affirmed
Sufficiency of evidence for accomplice liability	State instructed jury on accomplice theory; same circumstantial inferences could show intentional assistance or shared knowledge	Rostie argued evidence did not prove he aided or abetted J.W. in storing paraphernalia	Court upheld conviction as both principal and accomplice based on the same total circumstantial picture

State v. Fairbanks, 842 N.W.2d 297 (Minn. 2014) (standard for reviewing sufficiency of the evidence)
State v. Moore, 846 N.W.2d 83 (Minn. 2014) (two-step analysis for convictions based solely on circumstantial evidence)
State v. Jones, 516 N.W.2d 545 (Minn. 1994) (circumstantial-evidence convictions require a complete chain excluding all rational alternatives)
State v. Bauer, 598 N.W.2d 352 (Minn. 1999) (circumstantial evidence entitled to same weight as direct evidence)
State v. Webb, 440 N.W.2d 426 (Minn. 1989) (jury is best positioned to evaluate circumstantial evidence)