State v. Diggins, 836 N.W.2d 349

In October 2007 two men (Woods‑Wilson and Brown) were shot dead during a robbery in north Minneapolis; multiple eyewitnesses identified the shooter as a man nicknamed “Pops.”
Witnesses (K.C., L.E., A.A., and S.H.) identified Diggins from a photo lineup; Diggins was arrested wearing mechanic’s coveralls and carrying one victim’s driver’s license.
A grand jury indicted Diggins on two counts of first‑degree premeditated murder, two counts of first‑degree felony murder, and three counts of first‑degree aggravated robbery; he was convicted on all counts and sentenced to consecutive life terms for the murders.
During voir dire the State used a peremptory challenge to strike Juror 16 (African‑American); Diggins objected under Batson and the court overruled the objection after the State gave race‑neutral reasons and Diggins declined to rebut them.
Two days before trial Diggins assaulted and threatened witness S.H. in a jail holding cell; the court admitted testimony about that assault/threat as evidence of consciousness of guilt but gave a limiting instruction.
On appeal Diggins challenged the Batson ruling and admission of the jail assault/threat evidence; he also sought to file a late supplemental brief which the court denied.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the State’s peremptory strike of Juror 16 violated Batson (racial discrimination)	Diggins: strike was racially motivated; similar white jurors were not struck	State: articulated race‑neutral reasons (inconsistent questionnaire/voir dire answers; concerns about juror’s intellectual capacity); court found no prima facie showing and reasons race‑neutral	Court upheld the strike: State gave race‑neutral explanations; Diggins waived pretext argument and record does not clearly establish discrimination
Whether admitting evidence of the jail assault and threat was reversible error	Diggins: evidence was unfairly prejudicial, used to depict him as violent, and improperly bolstered S.H.’s credibility	State: assault/threat showed consciousness of guilt; court limited testimony and gave a cautionary instruction	Court affirmed admission: probative for consciousness of guilt, safeguards and limiting instruction prevented unfair prejudice
Whether the late motion for supplemental briefing should be allowed	Diggins: permit additional claims on sufficiency, prosecutorial misconduct, and jury instructions in interests of justice	State: untimely; no good cause for late filing	Court denied motion: untimely, filed months after counsel appearance and days before argument

Batson v. Kentucky, 476 U.S. 79 (prohibits racial discrimination in peremptory challenges)
Miller‑El v. Dretke, 545 U.S. 231 (evidence that similar nonminority juror wasn’t struck can show pretext)
Purkett v. Elem, 514 U.S. 765 (prosecutor’s explanation need not be persuasive; must be race neutral)
Hernandez v. New York, 500 U.S. 352 (Batson three‑step framework described)
Snyder v. Louisiana, 552 U.S. 472 (deference to trial court’s Batson credibility determinations)
State v. Scott, 493 N.W.2d 546 (defendant must timely present pretext argument or waive it on appeal unless record clearly establishes pretext)
State v. Harris, 521 N.W.2d 348 (threats against witnesses admissible to show consciousness of guilt)
State v. Mayhorn, 720 N.W.2d 776 (trial court discretion in admitting threat evidence and weighing unfair prejudice)
Holt v. State, 772 N.W.2d 470 (district court’s evidentiary rulings reviewed for abuse of discretion)