State of Minnesota v. Timothy John Huber, 877 N.W.2d 519

Timothy John Huber was tried and convicted (second-degree intentional murder and second-degree felony murder) on an accomplice-liability theory for the death of Timothy Larson; his father Delbert pleaded guilty to second-degree murder.
The jury instructions used hybrid accomplice-principal language: general accomplice instruction mentioned “intentionally aided” but the element listings for each charge repeatedly used “aided and abetted” without the word “intentionally.”
Huber did not object to the instructions at trial; appellate review therefore invoked the plain-error standard.
At trial Huber presented evidence that he did not know Delbert intended to shoot Larson, that he may have been in the barn (not at the altercation), and that he did not intend his presence or conduct to further any crime; Delbert testified Huber never touched the rifle and was not told of any plan to shoot Larson.
The State’s proof of intentional aiding was circumstantial and contested rather than overwhelming.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Huber)	Held
Whether jury instructions properly explained the statutory element “intentionally aiding” under Minn. Stat. § 609.05	Instructions were legally sufficient and any omission did not affect the verdict	Instructions failed to define or require intent for aiding and abetting; this omission misstated the law	Court: Instructions were plainly erroneous for (1) failing to explain what “intentionally aiding” means and (2) omitting "intentionally" in the element listings
Whether the plain error affected Huber’s substantial rights (prejudice prong)	Evidence of aiding was sufficient; error did not significantly affect verdict	Error was prejudicial because Huber vigorously contested intent and State’s proof was circumstantial and equivocal	Court: Huber met his heavy burden; the instruction error likely affected the verdict and thus his substantial rights
Whether a new trial is required (fairness/integrity prong)	A new trial not warranted because evidence supports conviction despite instruction error	A new trial is necessary to protect fairness because jury could convict based on mere presence or assistance absent intent	Court: Reversed and remanded for a new trial to protect fairness, integrity, and public reputation of proceedings

State v. Milton, 821 N.W.2d 789 (Minn. 2012) (requires jury instructions to explain the meaning of “intentionally aiding” as knowing the accomplice will commit the crime and intending one’s presence/actions to further it)
State v. Kelley, 855 N.W.2d 269 (Minn. 2014) (applies Milton; omitting explanation of intentionally aiding is plain error)
State v. Watkins, 840 N.W.2d 21 (Minn. 2013) (plain error where an instruction omitted an element of the offense)
State v. Griller, 583 N.W.2d 736 (Minn. 1998) (framework for plain-error review and discussion of when a new trial would be futile)
United States v. Olano, 507 U.S. 725 (1993) (federal standard on plain error: must affect substantial rights and seriously affect fairness, integrity, or public reputation to warrant correction)