State of Minnesota v. Tommy William Mix, A15-1578

Tommy Mix lived with his wife (K.M.) and daughter in a two-story house that had structural problems; he had been laid off and expressed to a friend a desire to "get rid of the house."
In the middle of the night a fire started in the kitchen near the stove; K.M. awoke twice, smelled gasoline, saw Mix downstairs, and later heard him scream that there was a fire.
Firefighters found a five-gallon gas can by the stove and two pans in the oven containing liquid that smelled like gasoline; BCA testing confirmed the liquid was gasoline and fire patterns indicated an ignitable liquid was used.
No forced entry was found and only Mix, his wife, and daughter were in the home when the fire began; Mix filed (and was denied) an insurance claim after the fire.
The state charged Mix with first-degree arson; a jury convicted him and he appealed arguing (1) insufficient evidence and (2) erroneous admission of his wife’s testimony over his spousal-privilege objection.

Issue	State's Argument	Mix's Argument	Held
Sufficiency of the evidence to prove Mix intentionally caused the fire	Evidence showed motive (financial distress), means (gas can, gasoline in pans), opportunity (only household members present), and fire patterns consistent with deliberate ignition; circumstantial proof sufficient	Evidence insufficient to exclude innocent hypotheses; motive evidence weak	Affirmed: under heightened circumstantial-evidence review, the proved circumstances were consistent only with guilt and supported conviction
Admission of spouse's testimony over spousal-privilege objection	Crime exception to marital privilege applies where the offense, as committed, posed a special danger to the spouse and thus was a crime against that spouse; wife and child were present and endangered	Crime-against-spouse exception does not apply because arson is a property offense and K.M. had no ownership interest; wife faced no special danger and cooperated with prosecution; privilege should bar live testimony	Affirmed: court holds first-degree arson (as committed here with wife and child present) poses special danger to human life, so crime exception applied; concurring judge would find error but deem it harmless

State v. DeRosier, 695 N.W.2d 97 (Minn. 2005) (standard for sufficiency-of-the-evidence review)
State v. Al‑Naseer, 788 N.W.2d 469 (Minn. 2010) (heightened two-step review for circumstantial evidence)
State v. Zais, 805 N.W.2d 32 (Minn. 2011) (framework for applying crime exception to marital privilege: consider elements and underlying conduct)
State v. Nunn, 297 N.W.2d 752 (Minn. 1980) (property offenses like burglary may pose special risks to human life and thus be crimes against a person)
State v. Expose, 872 N.W.2d 252 (Minn. 2015) (harmless-error analysis for erroneous admission of privileged testimony)