State v. Boldman, 813 N.W.2d 102

Boldman was convicted by jury of first-degree felony murder and second-degree intentional murder for the January 18, 2009 shooting death of Vernon Cafle in St. Paul, Minnesota.
The district court sentenced Boldman to life for the first-degree felony-murder conviction.
The State conceded the first-degree felony-murder conviction was not supported by the record and the Court vacated it.
Appellant argued insufficiency of the evidence for both convictions and claimed a discovery violation; the State argued discovery was satisfied and the first-degree murder predicate was supported.
The Court concluded the evidence did not support the first-degree felony-murder conviction but did support second-degree murder, and the alleged discovery violation was harmless; the matter was remanded for conviction and sentencing on the second-degree murder charge.
On remand, the district court should enter judgment and sentence on the second-degree murder charge.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether first-degree felony murder was supported by the record.	Boldman—purchased marijuana; no sale by Boldman.	State failed to prove unlawful sale predicate; Boldman was not the seller.	First-degree felony murder vacated; evidence insufficient for predicate.
Whether the evidence supports second-degree intentional murder.	Evidence shows intent to kill beyond reasonable doubt.	Shooting was accidental or self-defense.	Sufficient evidence to convict on second-degree intentional murder; affirmed remand for formal conviction and sentencing.
Whether the discovery violation was harmless.	State failed to provide transcript; potential prejudice.	Discovery violation affected defense; prejudicial.	Harmless beyond a reasonable doubt; no new trial necessary.

State v. Thompson, 578 N.W.2d 734 (Minn. 1998) (concession-supported record; discretion to accept State's concession)
State v. Palmer, 803 N.W.2d 727 (Minn. 2011) (principles for appellate review of sufficiency and circumstantial evidence)
State v. Leake, 699 N.W.2d 312 (Minn. 2005) (reasonable inferences from circumstantial evidence)
Bernhardt v. State, 684 N.W.2d 465 (Minn. 2004) (presumption of guilt beyond reasonable doubt guidance)
State v. Matthews, 800 N.W.2d 629 (Minn. 2011) (two-step test for circumstantial-evidence sufficiency)
State v. Andersen, 784 N.W.2d 320 (Minn. 2010) (circumstantial evidence evaluation framework)
State v. Pflepsen, 590 N.W.2d 759 (Minn. 1999) (remand for formal conviction and sentencing on lesser charge)
State v. Pflepsen, 590 N.W.2d 759 (Minn. 1999) (remand procedure (same case))
State v. Palubicki, 700 N.W.2d 476 (Minn. 2005) (discovery violation prejudice standard)
State v. Scanlon, 719 N.W.2d 674 (Minn. 2006) (prejudice assessment for discovery violations)
State v. Lahue, 585 N.W.2d 785 (Minn. 1998) (circumstantial-evidence evaluation standards)
State v. Richardson, 670 N.W.2d 267 (Minn. 2003) (use of force in self-defense context standards)
State v. Curtis, 295 N.W.2d 253 (Minn. 1980) (principles for evaluating competing inferences)