State of Minnesota v. Timothy Lee Heller, 12 N.W.3d 452

Timothy Heller was convicted of first-degree domestic abuse murder for causing the death of his girlfriend, Lacy Krube, in Hennepin County, Minnesota.
The prosecution presented evidence of Heller’s long pattern of domestic abuse involving multiple victims from the late 1990s to 2020.
The trial included challenged evidence: prior acts of abuse by Heller, expert testimony on domestic violence lethality factors, and certain alternative-perpetrator evidence related to J.R., Lacy’s ex-boyfriend.
The jury was instructed on venue (proper location for trial) and what constitutes a past pattern of domestic abuse; Heller challenged both instructions.
The district court admitted most of the State’s past-pattern evidence, allowed certain expert testimony, and excluded some evidence Heller sought to introduce regarding J.R. as an alternative perpetrator.

Issue	Heller's Argument	State's Argument	Held
Venue Instruction error	Venue instruction allowed conviction based on acts too remote	Venue was proper as all relevant acts occurred in Hennepin County	Any error was harmless beyond a reasonable doubt
Pattern of Domestic Abuse Jury Instruction	Jury could find pattern from singular acts against several	Pattern can consist of acts against different household/family victims	Instruction was correct; statutory pattern need not be multiple acts/same victim
Admission of Decades-Old Past Abuse	Acts too remote in time to show current pattern	Timeline shows consistent pattern without decades-long gaps	Admission not abuse of discretion; pattern shown by regular, proximate abuse
Admission of Lethality Factors Expert Testimony	Testimony is prejudicial profile evidence, not case-specific	Testimony provides helpful context on domestic violence dynamics	Admission was error but harmless as it played a minor role
Exclusion of Alternative-Perpetrator Evidence (re: J.R.)	Exclusion violates right to present a defense	Evidence was hearsay or improper character evidence	Exclusion proper under evidentiary rules; no violation of fair trial rights

State v. Sanchez-Diaz, 683 N.W.2d 824 (Minn. 2004) (pattern of abuse can be shown by acts against different family members)
State v. Clark, 739 N.W.2d 412 (Minn. 2007) (remoteness in time of abuse can make evidence irrelevant to pattern)
State v. Cross, 577 N.W.2d 721 (Minn. 1998) (no statutory minimum number of incidents to establish a pattern)
State v. Vang, 774 N.W.2d 566 (Minn. 2009) (jury instructions must adequately explain the law)
State v. Williams, 525 N.W.2d 538 (Minn. 1994) (court disapproves of profile evidence such as drug courier profile)
State v. Loebach, 310 N.W.2d 58 (Minn. 1981) (inadmissibility of profile evidence, e.g., battering parent profile)
State v. Hawkins, 260 N.W.2d 150 (Minn. 1977) (requirements for alternative-perpetrator evidence)
State v. Nunn, 561 N.W.2d 902 (Minn. 1997) (review of evidentiary rulings for abuse of discretion)