State of Minnesota v. Nisius Dealvin McAllister, 862 N.W.2d 49

Victim Michael McMillan was brutally beaten and robbed in a Minneapolis alley by three men: appellant Nisius McAllister and his nephews Leondis McAllister and Justin Fineday; the victim was later shot and died of complications from gunshot wounds.
Eyewitnesses described a prolonged, coordinated beating, stripping of the victim, theft of possessions, and at least one return to the scene to fire another shot; police arrested all three nearby and found items belonging to the victim and a .380 pistol in the vicinity.
McAllister was recorded in multiple police interviews: he admitted participating in the beating but initially refused to identify the shooter, later made incriminating statements identifying Fineday, and then recanted portions at a follow-up interview.
McAllister moved to suppress portions of post-"no . . . ain’t no sense in talking no more" statements as an invocation of the right to remain silent; the district court denied suppression and the recordings were played at trial.
A jury convicted McAllister of first-degree premeditated murder and first-degree felony murder; the court entered judgment on first-degree premeditated murder and sentenced him to life without release. McAllister appealed, arguing (1) insufficient evidence that he intentionally aided murder and (2) error admitting interrogation recordings after an alleged invocation of silence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for accomplice liability to first-degree premeditated murder	State: Circumstantial evidence shows McAllister intentionally aided the aggravated robbery and, under Minn. Stat. § 609.05 subdivision 2, is liable for the murder as a reasonably foreseeable consequence	McAllister: He did not intend or foresee a murder; he did not know a gun would be used and thus cannot be guilty of first-degree premeditated murder	Court: Affirmed — evidence supports accomplice liability for aggravated robbery, murder was in furtherance of robbery and reasonably foreseeable, so conviction stands under § 609.05 subd. 2
Admissibility of post-invocation interrogation statements (Miranda right to remain silent)	State: Statements were not an unequivocal invocation; even if erroneous admission, any error was harmless beyond a reasonable doubt	McAllister: His statement amounted to invocation of right to silence; subsequent statements should have been suppressed and their admission was prejudicial	Court: Need not decide unequivocal-invocation question; any error was harmless beyond a reasonable doubt given overwhelming, cumulative evidence of guilt and presentation context

State v. Milton, 821 N.W.2d 789 (Minn. 2012) (defining elements of accomplice liability and “intentionally aids”)
State v. Mahkuk, 736 N.W.2d 675 (Minn. 2007) (discussing knowledge and intent requirements for accomplice liability)
State v. Swanson, 707 N.W.2d 645 (Minn. 2006) (accomplice liability under subdivision 2 and in‑furtherance/foreseeability analysis)
State v. Pierson, 530 N.W.2d 784 (Minn. 1995) (shooting in furtherance of robbery when resistance occurs)
State v. Souvannarath, 545 N.W.2d 30 (Minn. 1996) (accomplice need not share the mens rea of the principal offense to be guilty under accomplice liability)
State v. Juarez, 572 N.W.2d 286 (Minn. 1997) (harmless‑error standard for constitutional trial errors)
State v. Robinson, 427 N.W.2d 217 (Minn. 1988) (admission of self‑incriminating statements requires harmless‑error review when erroneous)
State v. Al‑Naseer, 690 N.W.2d 744 (Minn. 2005) (factors for assessing prejudice from improperly admitted evidence)
State v. McDonald‑Richards, 840 N.W.2d 9 (Minn. 2013) (cumulative evidence and impeachment value of improperly admitted statements)