State v. Beecroft, 2012 Minn. LEXIS 209

Beecroft was convicted of first‑degree premeditated murder of her newborn; she was 17 years, 9 months old at the death.
Trial was to the bench; Beecroft challenged interference with defense experts and the admissibility of a police interview confession.
State actors interfered with Beecroft’s defense by pressuring and altering availability of key medical examiners (Roe, Ophoven).
The postconviction court denied relief; the supreme court granted consolidation and reviewed direct and postconviction appeals together.
Court of appeals held that the interference violated Beecroft’s due process rights but that the error did not affect substantial rights; nonetheless, the court reversed in the interests of justice due to the independence of medical examiners.
The plurality ultimately reversed Beecroft’s conviction and remanded for a new trial, while addressing Miranda rights and admissibility of the hospital statement.

Issue	Plaintiff's Argument	Defendant's Argument	Held
State actors’ interference violated due process?	Beecroft claims Backstrom’s emails and Uncini’s restrictions substantially interfered with defense witnesses.	Beecroft argues interference harmed her ability to present a complete defense.	Yes; substantial interference occurred and, under the circumstances, reversal in the interests of justice warranted.
Was defense counsel ineffective for failing to raise the due‑process issue?	Beecroft contends counsel failed to vigorously pursue the interference claim.	Counsel’s strategic decisions may have caused the inaction.	Remand for new trial on interests‑of‑justice grounds; partial sympathy with ineffective assistance claim but supreme court grants new trial.
Was Beecroft’s hospital‑interview confession properly admitted under Miranda?	Beecroft contends Miranda warnings were inadequate and waiver involuntary.	State contends warnings were adequate and waiver voluntary.	Miranda warning adequate; waiver voluntary; admission at hospital upheld.
May the court exercise supervisory power to reverse in interests of justice?	Beecroft seeks reversal to protect integrity of justice and medical examiners’ independence.	State argues such reversal should be reserved for error plus prejudice.	Yes; exceptional circumstances warrant reversal to protect independence of medical examiners and fair administration of justice.

Washington v. Texas, 388 U.S. 14 (U.S. (1967)) (right to present witnesses and defense)
Ake v. Oklahoma, 470 U.S. 68 (U.S. (1985)) (right to expert assistance for indigents when a significant trial factor)
Strickland v. Washington, 466 U.S. 668 (U.S. (1984)) (standard for ineffective assistance of counsel)
Backstrom (In re), 767 N.W.2d 453 (Minn. 2009) (prosecutor misconduct crossing into professional discipline; state action context)
Graham, 764 N.W.2d 340 (Minn. 2009) (due process right to present a defense; interference analysis)
Kaiser, 486 N.W.2d 384 (Minn. 1992) (interests of justice as a reversal basis)
Schwantes, 314 N.W.2d 243 (Minn. 1982) (predecessor on interests‑of‑justice reversals)
Windish, 590 N.W.2d 311 (Minn. 1999) (interests of justice reversal framework)
Ramey, 721 N.W.2d 294 (Minn. 2006) (prosecutor’s duty to seek justice; limits on misconduct)
Barefoot v. Estelle, 463 U.S. 880 (U.S. (1983)) (cross‑examination and reliability of expert testimony)