State v. Carridine
2012 Minn. LEXIS 183
| Minn. | 2012Background
- Carridine was convicted of first-degree premeditated murder for shooting Lorenzo Guffie outside Palmer’s Bar in Minneapolis (June 3, 2007).
- He testified self-defense and lack of intent to kill; the State presented eyewitnesses and B.J., L.W., and P.S. observed the events outside the bar.
- Carridine challenged the State’s use of two peremptory strikes against jurors of color (J.C. and P.G.).
- The district court admitted limited impeachment using Carridine’s prior statement from a 2008 letter for cross-examination.
- The court gave jury instructions including CRIMJIG 7.05 (justifiable taking of life) and 7.07 (revival of aggressor’s right) over objections.
- Carridine appeals on Batson, evidentiary impeachment, jury instructions, prosecutorial conduct, and recusal, all of which the court addresses on appeal.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Batson challenge to J.C. | Carridine: State used race-based strike; prima facie shown. | State gave race-neutral reasons; no pretext. | No reversible error; district court found no purposeful discrimination. |
| Batson challenge to P.G. | Carridine: third party color-strike with pretext risk. | Hesitancy reason race-neutral; not similarly situated with other jurors. | District court did not err; no prima facie showing and reasons upheld. |
| Admission of prior statement for impeachment | Rule 410 violation; prejudicial credibility impact. | Impeachment is minimal; not substantial influence on verdict. | Admission not prejudicial; substantial rights not affected. |
| Jury instructions on justifiable taking of life (CRIMJIG 7.05) | Error to give when self-defense claim negates intent. | Instruction plain error; misstates law. | Error did not affect substantial rights; invited-error doctrine applied; waived. |
| Revival of aggressor’s right of self-defense (CRIMJIG 7.07) | Instruction improper given Garridine’s conduct. | Substantial evidence he was initial aggressor; instruction appropriate. | District court did not abuse discretion; instruction supported by record. |
| Prosecutorial misconduct of closing/voir dire | State improperly injected bias and shifted burden; denigrated defense. | Misconduct either harmless or not prejudicial; proper instructions given. | Misconduct deemed harmless or not prejudicial; not grounds for reversal. |
Key Cases Cited
- State v. Greenleaf, 591 N.W.2d 488 (Minn. 1999) (peremptory strikes based on race; Batson framework)
- Batson v. Kentucky, 476 U.S. 79 (U.S. 1986) (establishes race-based peremptory challenge prohibition)
- State v. Martin, 773 N.W.2d 89 (Minn. 2009) (deferential Batson analysis; race-neutral reasons)
- Walton v. Caspari, 916 F.2d 1352 (8th Cir. 1990) (pretext may be shown by disparate treatment of similarly situated jurors)
- State v. Edwards, 717 N.W.2d 405 (Minn. 2006) (discusses aggression-start points and revival analysis)
- State v. Ray, 659 N.W.2d 736 (Minn. 2003) (voir dire can reveal bias; improper to invite socio-economic considerations)