State v. Brown
815 N.W.2d 609
| Minn. | 2012Background
- Brown was convicted in March 2010 of aiding and abetting first‑degree murder for the benefit of a gang in Miller’s death (Aug. 29, 2008).
- The State linked Brown to the Miller murder via a .9mm shell casing match to a Richfield 2008 shooting Brown had pled guilty to; Brown challenged the use of that evidence.
- Evidence at trial included gang testimony (lay and expert) about the Shotgun Crips; eyewitness identification; and jail surveillance linking Brown to the club scene.
- The State introduced evidence tying Brown to the Richfield shooting, including a jail video of Brown leaving jail with a ponytail and necklace 12 hours before Miller’s death, and a transcript excerpt from Brown’s Richfield plea.
- A post‑trial Brady issue arose when the State disclosed an additional plea deal for C.W.; the postconviction court denied relief, and the direct appeal was consolidated with postconviction review.
- Brown contends five errors on appeal: public trial closure, admission of Richfield evidence, plain error in jury instructions, plain error in gang testimony, and Brady impeachment disclosure; the court affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Public trial closure during jury instructions | Brown argues closure violated public trial right | State contends closure did not implicate public trial | Not a public-trial violation; affirmed |
| Admissibility of Richfield shooting evidence under Rule 404(b) | Brown claims not inextricably intertwined; improper under Spreigl | State argues admissible to prove identity/opportunity and intertwined | Admissible under Rule 404(b) and intertwined rationale |
| Plain error in admitting gang expert testimony | Brown asserts clear, obvious error in expert testimony | State contends testimony was proper and non‑prejudicial | No plain error; admission affirmed |
| Plain error in aiding-and-abetting jury instructions | Instructions improperly lowered intent requirement | Instructions correctly stated elements and burden | No plain error; jury instructions proper |
| State failure to disclose impeachment evidence (Brady) | Undisclosed plea deal impeachment evidence material to trial | Evidence not material to guilt/punishment | Not material; no new trial warranted |
Key Cases Cited
- Waller v. Georgia, 467 U.S. 39 (U.S. 1984) (public trial closure standard; structural error considerations)
- Presley v. Georgia, 130 S. Ct. 721 (S. Ct. 2010) (public trial applicability to all trial phases; openness duty)
- Lindsey v. State, 632 N.W.2d 652 (Minn. 2001) (trivial closures not implicating public trial rights)
- Caldwell v. State, 803 N.W.2d 373 (Minn. 2011) (public trial closure considerations in partial closures)
- Mahkuk v. State, 736 N.W.2d 675 (Minn. 2007) (public trial partial closures; framework for closure analyses)
- Sweeney v. State, 180 Minn. 450 (Minn. 1930) (general rule excluding other-crime evidence; exceptions (motive/identity/etc.))
- Wofford v. State, 262 Minn. 112 (Minn. 1962) (evidence of prior gun possession admissible for identity/opportunity; Rule 404(b) context)