State v. Castillo-Alvarez, 836 N.W.2d 527

Castillo-Alvarez challenges his Minnesota convictions for second-degree murder and kidnapping; argues §609.045 and Minnesota Double Jeopardy Clause bar prosecution.
Iowa convictions for the same conduct were reversed on appeal; Minnesota prosecutions proceeded later with charges of aiding and abetting murder and kidnapping.
Castillo-Alvarez alleged admission was obtained via an unrecorded custodial interrogation; Minnesota and Iowa/Federal officers conducted the interview.
Interrogation occurred in Texas with an FBI agent and an Iowa sheriff; Minnesota officers had no involvement; interview was preparatory for Iowa prosecution.
Minnesota Court of Appeals affirmed; district court admitted unrecorded statement; this Court granted review.
Castillo-Alvarez was extradited from Mexico; after Iowa appeal reversal, Minnesota filed complaints; trial and conviction followed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether §609.045 bars Minnesota prosecution	Castillo-Alvarez argues Iowa conviction blocks Minnesota case	State contends no bar since Iowa conviction reversed	No bar; final conviction requirement not met due to reversal
Whether Minnesota Constitution double jeopardy prevents prosecution	Castillo-Alvarez seeks broader protection than federal law	Heath dual-sovereignty doctrine permits separate prosecutions	Minnesota allows successive state prosecutions; no violation
Whether admission of unrecorded out-of-state interrogation violated Scales	Scales applies to out-of-state interrogation; violation substantial	Scales is procedural; substantiality not shown	Scales applies; not substantial; admission upheld
What choice-of-law applies to Scales question	Lex fori should apply; Minnesota rule controls	Most significant relationship governs	Most significant relationship applies; Iowa had most significant relation to interrogation
Scope of Scales rule: procedural or substantive	Scales is both procedural and substantive	Scales is procedural only	Scales is procedural; not a substantive bar to admission

State v. Spaulding, 296 N.W.2d 870 (Minn. 1980) (final conviction requirement in multi-offense context)
State v. Schmidt, 612 N.W.2d 871 (Minn. 2000) (final-conviction concept in double jeopardy/6th sense)
State v. Lucas, 372 N.W.2d 731 (Minn. 1985) (exclusionary rule approach to out-of-state evidence)
State v. Heaney, 689 N.W.2d 168 (Minn. 2004) (most significant relationship approach for privilege issues)
State v. Scales, 518 N.W.2d 587 (Minn. 1994) (mandatory recording of custodial interrogations; substantial-violation standard)