State v. Craig, 807 N.W.2d 453

Craig was convicted of possession of a firearm by an ineligible person under Minn.Stat. § 624.713, subd. 1(2) after police stopped his maroon car following a domestic-disturbance call.
A deputy conducted a warrantless inventory-style search of the car and found a .22 caliber revolver in an unzipped backpack on the front passenger seat; DNA testing yielded mixed results on the gun grip, not excluding Craig.
Craig had a 2008 felony conviction for a controlled-substance offense, making him ineligible to possess a firearm under the statute.
The district court admitted Craig’s prior controlled-substance conviction for impeachment purposes; Craig testified, denying knowledge of the gun.
S.Y., the complainant, was unavailable to testify; her prior burglary convictions were offered for impeachment but the district court initially excluded them; the gun’s DNA and surrounding testimony were central to Craig’s defense.
Craig was sentenced to the mandatory minimum 60 months and ordered a $75 public defender copayment.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Second Amendment challenge to § 624.713, subd. 1(2)	Craig argues statute violates the Second Amendment as applied.	State argues the statute is permissible and presumptively lawful.	Statute survives intermediate scrutiny; constitutional as applied.
Validity of warrantless car search	Craig contends suppression of firearm evidence is warranted due to illegality.	State asserts automobile exception applies.	Automobile exception applies; suppression not required.
Waiver of jury-trial on stipulated element	Craig argues his waiver for the stipulated element was inadequate.	State contends any error was harmless.	Harmless error; no reversible defect in waiver.
Impeachment by prior controlled-substance conviction	Craig challenges admissibility under Jones factors.	State urges admission as impeachment; sufficient factors support it.	Admission upheld; all Jones factors weigh in favor of admissibility.
Impeachment of unavailable witness via hearsay	Craig seeks impeachment of S.Y.’s hearsay via prior convictions.	State argues exclusion was proper; no hearsay basis to impeach.	Ruling upheld; exclusion harmless if error occurred.

District of Columbia v. Heller, 554 U.S. 570 (U.S. 2008) (establishes core Second Amendment right to keep and bear arms)
McDonald v. City of Chicago, 130 S. Ct. 3020 (U.S. 2010) (incorporation of Second Amendment to states)
Clark v. Jeter, 486 U.S. 456 (U.S. 1988) (test for substantial relation under intermediate scrutiny)
State v. Bussmann, 741 N.W.2d 79 (Minn. 2007) (presumption of constitutionality and deference to statute)
Fluker v. State, 781 N.W.2d 397 (Minn. 2010) (harmless error in lacking explicit waiver for stipulated elements)
State v. Jones, 271 N.W.2d 534 (Minn. 1978) (Jones factors for balancing probative value vs prejudice)
Tlapa v. State, 642 N.W.2d 72 (Minn. App. 2002) (plain-error review when stipulating elements without full waiver)
United States v. Marzzarella, 614 F.3d 85 (3d Cir. 2010) (structured discussion of intermediate scrutiny for felon-in-possession)
United States v. Rozier, 598 F.3d 768 (11th Cir. 2010) (presumptively lawful exceptions under Heller survive scrutiny)