State v. Fairbanks, 842 N.W.2d 297

Fairbanks convicted by jury of multiple felonies including first-degree murder of a peace officer and related offenses arising from Deputy Dewey shooting.
Venue was transferred from Mahnomen to Polk County over Fairbanks's objection on prejudicial publicity and racial demographics considerations.
Deputy Dewey died 18 months after the shooting; trial proceeded on murder charge despite year-and-a-day rule.
Autopsy and spark-of-life photographs were admitted and displayed; Fairbanks challenged their admissibility and prejudicial effect.
Jury found Fairbanks guilty on all counts except one first-degree assault conviction which the court later reversed on appeal.
On appeal, the court reversed a single count of first-degree assault but affirmed the remainder, including the murder conviction and other felonies.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Venue transfer abuse of discretion	Fairbanks argues Polk County did not cure prejudicial publicity.	Fairbanks contends relocation was improper due to publicity and demographics.	No abuse; district court properly weighed factors and mitigated publicity.
Year-and-a-day rule applicability	Fairbanks contends the rule bars murder charge.	State argues rule never applied under Minnesota law post-1963 code.	Rule does not apply; statute permits murder indictments regardless of death date.
Admission of autopsy and spark-of-life photos	Photos were graphic and prejudicial; violated fair trial.	Photos were relevant to causation and properly admitted.	No abuse; photos relevant and properly admitted with appropriate limiting instructions.
Sufficiency of evidence for four counts of first-degree assault	Circumstantial evidence could fit alternate explanations; guilty verdicts insufficient.	Circumstantial evidence, viewed in light of all inferences, supports guilt.	Counts III–V supported; Count VIII (east-side shots) reversed for lack of sufficient evidence linking timing to guilt.

State v. Blom, 682 N.W.2d 578 (Minn. 2004) (standard for abuse of discretion in venue transfers; multiple factors considered)
State v. Fratzke, 354 N.W.2d 402 (Minn. 1984) (venue change considerations; abuse of discretion review)
State v. Webber, 292 N.W.2d 5 (Minn. 1980) (venue transfer; review of trial court discretion)
State v. Warren, 592 N.W.2d 440 (Minn. 1999) (actual prejudice from pretrial publicity required for change of venue)
State v. Morrow, 834 N.W.2d 715 (Minn. 2013) (admissibility and use of photographs; spark-of-life evidence)
State v. Hummel, 483 N.W.2d 68 (Minn. 1992) (admissibility of graphic photographs; relevance and impact on theory of causation)