State v. Davis, 820 N.W.2d 525

Davis was convicted of aiding and abetting first-degree felony murder for Calix’s death; district court sentenced him to life in prison.
Calix bled to death after a neck gunshot at ~8:00 p.m. on May 11, 2007; investigation tied Davis or accomplice Dorman to aggravated robbery and murder.
Davis made inculpatory statements about planned robbery on May 10, 2007 in a recorded jailhouse call with Anthony Whigham.
On May 11, 2007 Davis met with Jovan Gentle about a missing watch; Dorman accompanied Davis during the events near Calix’s apartment, with later discovery of marijuana and guns.
Cell phone records and eyewitness B.B. placed Davis and Dorman near the crime scene and entering Calix’s building just before the shooting.
Davis was arrested May 18, 2007, interrogated, and gave a statement after Miranda warnings; portions of the statement were argued to be involuntary or inadmissible.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the May 18 statement should have been suppressed	Davis argues the statement was involuntary or obtained after a silence violation	State contends any error was harmless, and the admissible portion already harmed credibility	Harmless beyond a reasonable doubt; no new trial required
Whether Gentle’s fear testimony on redirect was plain error	Fear testimony was improperly admitted without limits	State concedes error but argues no substantial impact on verdict	No plain error affecting substantial rights; not reversible
Whether M.N. and W.H. hearsay statements were admissible	Statements should be admitted under excited utterance or residual exception	District court properly excluded; lack of stress/excitation and credibility concerns	District court did not abuse discretion; statements inadmissible
Whether no-adverse-inference instruction given without consent was plain error	Instruction violated Davis’s rights and could affect verdict	Instruction harmless given strength of evidence and Davis’s trial strategy	Plain error but harmless; no reversal
Whether cumulative errors entitle a new trial	Cumulative impact prejudiced defense	Evidence of guilt strong; errors not prejudicial	No new trial based on cumulative errors

State v. Larson, 788 N.W.2d 25 (Minn. 2010) (harmless-error standard for constitutional trial errors)
State v. Ferguson, 804 N.W.2d 586 (Minn. 2011) (harmlessness review for constitutional errors)
State v. Buckingham, 772 N.W.2d 64 (Minn. 2009) (presence at scene does not prove aiding/abetting; cumulative analysis)
State v. Griller, 583 N.W.2d 736 (Minn. 1998) (plain-error framework for unobjected trial errors)
State v. Gomez, 721 N.W.2d 871 (Minn. 2006) (no-adverse-inference instruction; prejudice assessment)