State of Minnesota v. Patrick Allison Baker, A15-2086

Baker and C.E. were long-term partners; both were legally prohibited from possessing firearms due to prior felonies.
C.E. lived with her sister S.H.; Baker sometimes stayed secretly despite being barred from the house.
C.E. observed Baker with a dark shotgun twice and later saw the gun hidden in a bedroom vent at S.H.’s home.
Police recovered the shotgun from the vent; BCA testing matched a fingerprint near the trigger to Baker’s right index finger.
Baker was charged with being a prohibited person in possession of a firearm and possession of a short-barreled shotgun; a court trial convicted him of both counts.

Issue	State's Argument	Baker's Argument	Held
Whether C.E. was an accomplice such that her testimony required corroboration	C.E. was a witness who implicated Baker; her testimony supported conviction	C.E. should be treated as an accomplice because she was also prohibited and the gun was in her room, so her testimony required corroboration	Court held C.E. was portrayed as an alternative perpetrator, not an accomplice, so corroboration rule did not apply
Whether convictions must be reversed for insufficient evidence due to uncorroborated accomplice testimony	Testimony plus fingerprint evidence supported convictions	Convictions rest on uncorroborated accomplice testimony and thus are insufficient	Court reviewed de novo whether C.E. was an accomplice and affirmed convictions because C.E. was an alternative suspect and fingerprint plus testimony supported verdict

State v. Scruggs, 822 N.W.2d 631 (explains legal distinction between accomplice status and sufficiency review)
State v. Reed, 737 N.W.2d 572 (sets test whether a witness could be indicted and convicted to determine accomplice status)
State v. Swanson, 707 N.W.2d 645 (holds a witness portrayed as alternative perpetrator is not an accomplice)
State v. Larson, 787 N.W.2d 592 (reinforces that portraying a witness as alternative perpetrator removes accomplice status)