State v. Gatson, 801 N.W.2d 134

Gatson indicted July 5, 2007 for first-degree murder, second-degree murder, and first-degree assault under Minn. Stat. §§ 609.185(a)(1), 609.19, subd. 1(1), 609.221, subd. 1 (2010).
October 30, 2009 jury verdict: guilty on all counts; trial court denied new trial; sentenced to life without release for murder and 86 months for assault, concurrent.
Shyloe Linde was pregnant with Gatson’s baby Destiny Gatson; Destiny born prematurely on April 21, 2007, placed on life support, and died after life-support removal on May 1, 2007.
Gatson allegedly aided Petersen in Linde’s assault and Destiny’s death; evidence included fabricated alibi, calls to Linde, driving Petersen, and sending Petersen to see Linde; Petersen pleaded guilty and a transcript of his plea was read; Gatson allegedly procured Raleigh to threaten Petersen, affecting testimony.
Gatson challenged Batson discrimination, sufficiency of evidence, jury instructions on human being and superseding cause, lesser-included offenses, admissibility of Petersen’s plea, opening statements about Petersen, and newly discovered evidence; convictions affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Batson challenge to juror R.R.	Gatson argues State struck R.R. due to race (Batson).	State asserts race-neutral reason: R.R. not forthright about friend’s trial.	No pretext; strike upheld.
Sufficiency of evidence for aiding Petersen	Gatson contends insufficient proof he knowingly aided Petersen.	State argues circumstantial evidence proves aiding beyond reasonable doubt.	Sufficient evidence to sustain conviction.
Destiny as a human being and causation	Destiny was not a ‘human being’ and causation unclear.	Destiny was born alive and independent; life-support removal foreseeable; causation shown.	Destiny born alive; removal not superseding; causation proven.
Lesser-included offenses instruction	Failure to submit attempted murder/first-degree assault as lesser-included offenses.	No prejudicial impact given other evidence; not error.	No abuse of discretion; harmless in any event.
Admission of Petersen’s plea and hearsay	Admission violated confrontation/hearsay rules; prejudicial.	Error harmless beyond reasonable doubt; overwhelming guilt evidence.	Harmless beyond a reasonable doubt.

Batson v. Kentucky, 476 U.S. 79 (U.S. 1986) (racial discrimination in jury selection prohibition)
Greenleaf v. State, 591 N.W.2d 488 (Minn. 1999) (three-step Batson framework; deference to trial court on credibility)
Miller-El v. Dretke, 545 U.S. 231 (U.S. 2005) (pretext inquiry requires evaluating plausibility of proffered race-neutral reason)
State v. Soto, 378 N.W.2d 625 (Minn. 1985) (definition of ‘human being’ in homicide context; must be born alive with independent existence)
State v. Olson, 435 N.W.2d 530 (Minn. 1989) (causation; superseding intervening cause; foreseeability of medical intervention)
State v. Pendleton, 567 N.W.2d 265 (Minn. 1997) (instructional error review; fundamental-law questions handled as plain error)
State v. Caulfield, 722 N.W.2d 304 (Minn. 2006) (confrontation and forfeiture-by-wrongdoing analysis applied)
Williamson v. United States, 512 U.S. 594 (U.S. 1994) (three-step analysis for declarations against penal interest)
State v. Cox, 779 N.W.2d 844 (Minn. 2010) (forfeiture-by-wrongdoing and confrontation principles applied)