State v. Caldwell
2011 Minn. LEXIS 545
| Minn. | 2011Background
- Caldwell convicted in Hennepin County of aiding and abetting first-degree murder for the benefit of a gang; sentenced to life without release.
- Kirk Harrison, the principal shooter, was acquitted of first-degree murder, but Caldwell’s conviction was upheld under Minn. Stat. § 609.05, subd. 4.
- Evidence at trial included Caldwell driving the SUV from which shots were fired, gang affiliation testimony, and a gun-handling sequence involving Caldwell and Harrison.
- Witnesses described the LL gang with a common sign; the group confronted the One-Nine gang; prosecutors framed the shooting as part of gang rivalry.
- Caldwell pursued postconviction relief on several bases (nonmutual collateral estoppel, ineffective assistance; newly discovered evidence), which the postconviction court denied; this Court affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Effect of § 609.05, subd. 4 when principal acquitted | Caldwell: acquittal excludes conviction. | Hester supports statute permits conviction. | Statute permits Caldwell’s conviction despite Harrison’s acquittal. |
| Sufficiency of evidence of Harrison's intent and premeditation | Caldwell contends no proof of principal’s premeditation. | Harrison’s intent shown by gang rivalry and planned targeting. | Sufficient evidence supports premeditation and intent. |
| LL gang as a statutory gang | Not shown LL meets statutory gang criteria. | LL has three+ members, common sign, and pattern of criminal activity. | Sufficient evidence LL met statutory definition of a gang. |
| Ineffective assistance of counsel | Voir dire and attorney-client relationship were deficient. | Counsel acted reasonably; no prejudice shown. | No reversible ineffective-assistance error; defenses not prejudiced. |
| Newly discovered evidence entitling an evidentiary hearing | Kirk Harrison/barber affidavits show Caldwell lacked knowledge of a gun. | First prong of Rainer not satisfied; evidence not unknown. | No entitlement to evidentiary hearing; first Rainer prong not satisfied. |
Key Cases Cited
- State v. Hester, 796 N.W.2d 328 (Minn. 2011) (statutory interpretation and de novo review on § 609.05(4))
- State v. Cegon, 309 N.W.2d 313 (Minn. 1981) (acquittal of principal does not bar aiding-and-abetting conviction)
- State v. Webb, 440 N.W.2d 426 (Minn. 1989) (sufficiency of evidence standard and jury deference)
- State v. Rhodes, 657 N.W.2d 823 (Minn. 2003) (ineffective assistance framework and prejudice showing)
- State v. Turnipseed, 297 N.W.2d 308 (Minn. 1980) (circumstantial-evidence instruction and evidentiary standards)
- Morris v. Slappy, 461 U.S. 1 (U.S. 1983) (right to counsel and meaning of effective assistance)