State v. Ferguson
2011 Minn. LEXIS 644
| Minn. | 2011Background
- Irene Burks was shot and died in September 2006; Ferguson was later tried for first-degree murder.
- KC testified saw a hooded black-male shooter; a brown sedan and gunfire followed Burks’s car.
- The State presented witness testimony and Ferguson’s Edwards federal trial testimony linking street names C.J./B.J. to the shooter.
- KC identified Ferguson in a six-photo lineup; no physical evidence linked Ferguson to the crime.
- Ferguson sought to introduce evidence that Christopher Jennings (also C.J.) was the alternative perpetrator; the court limited this.
- The jury convicted Ferguson; he received life without parole; the court later reversed and remanded for a new trial on the alternative-perpetrator issue.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of alternative-perpetrator evidence | Ferguson’s evidence of Jennings had inherent tendency to connect to the crime. | Exclusion violated Ferguson’s right to present a complete defense. | District court erred; reversal and new trial |
| Admissibility of hearsay C.J./B.J. statements about the shooter | Hearsay evidence provided context for investigation, not to prove guilt. | Statements were inadmissible hearsay and unfairly prejudicial. | Error admitted; context evidence improper |
| Admission of Ferguson's Edwards testimony under Rule 404(b) | Edwards testimony corroborated other witnesses and spanned relevant issues. | Testimony was improper 404(b) corroboration and violated rights. | Admissibility error; improper use under 404(b) |
| Prosecutorial misconduct related to police contacts and closing argument | Leading questions and misstatements impermissibly implied bad character and evidence. | Misconduct was not reversible error or prejudicial. | Misconduct occurred; potential prejudice |
| Impeachment of Derrick Johnson with prior statements | Johnson’s prior inconsistent statements and reputation evidence were admissible to impeach credibility. | Impeachment evidence was improperly excluded or limited. | Court abused discretion; impeachment evidence should have been allowed |
Key Cases Cited
- State v. Hall, 764 N.W.2d 837 (Minn. 2009) (harmless-error standard for constitutional error)
- State v. Larson, 787 N.W.2d 592 (Minn. 2010) (complete-defense right includes alternative-perpetrator evidence)
- State v. Atkinson, 774 N.W.2d 584 (Minn. 2009) (threshold connection requirement for alternative-perpetrator evidence)
- State v. Nissalke, 801 N.W.2d 82 (Minn. 2011) (inherent tendency standard for 404(b) evidence)
- State v. Jones, 678 N.W.2d 1 (Minn. 2004) (use of 404(b) evidence to prove non-character purposes)
- Litzau, 650 N.W.2d 177 (Minn. 2002) (non-hearsay purpose and 403 balancing for investigative background)
- State v. Helterbridle, 301 N.W.2d 545 (Minn. 1980) (eyewitness identification expert testimony admissibility discretion)
- State v. Miles, 585 N.W.2d 368 (Minn. 1998) (safeguards for eyewitness identification and limits on expert testimony)
- State v. Harris, 560 N.W.2d 672 (Minn. 1997) (prejudice concerns with 404(b) evidence; corroboration limits)
- Crawford v. Washington, 541 U.S. 36 (U.S. 2004) (confrontation rights and testimonial statements)