State v. Griffin, 846 N.W.2d 93

Griffin (defendant) was convicted by a jury of first- and third-degree criminal sexual conduct; victim S.L.B. testified he raped her; Griffin claimed consensual sex.
Before trial, defense challenged the jury venire composition, asserting underrepresentation of Black persons; challenge was denied at trial and renewed post-verdict with census and county jury-list data.
Postverdict evidence showed Olmsted County juries averaged ~1.29%–1.72% Black over 2010–mid‑2012; the 2010 census showed 4.8% of county population self‑identified as Black.
The district court admitted three of Griffin’s prior felony convictions for impeachment (one sexual‑offense conviction was admitted only as an unspecified felony per Hill), and the convictions were referenced briefly at trial.
The judge misread one word in the oral jury instruction for third‑degree CSC (said “sexual” instead of “social”), re‑read the instruction, and no counsel objected; correct written instructions were provided to the jury.
On appeal, Griffin argued (1) fair‑cross‑section violation, (2) erroneous admission of prior convictions, and (3) prejudicial misreading of the jury instruction; the appellate court affirmed.

Issue	Griffin's Argument	State's Argument	Held
Fair‑cross‑section violation	Jury venire underrepresented Black persons versus 2010 census, showing systematic exclusion	Census comparison is unreliable; small numerical differences are inevitable and alternative explanations (ineligible persons, minors, non‑citizens, no‑shows) explain disparity	Affirmed: Griffin failed to make prima facie showing of systematic exclusion; raw census-vs‑venire comparison insufficient
Admissibility of prior convictions for impeachment	Prior felonies were more prejudicial than probative; unnamed felony invites jurors to "assume the worst"	District court applied Jones factors and limited the similar sexual conviction to an unspecified felony per Hill to reduce prejudice	Affirmed: No abuse of discretion; Jones analysis proper and presentation minimized prejudice
Jury‑instruction misreading	Substituting “sexual” for “social” could have confused jury about admissibility of evidence of prior sexual relationship	The misstatement was a fleeting, unobjected‑to slip; correct written instructions were provided; not a fundamental legal error	Affirmed: No plain error; mistake did not affect substantial rights
Pro se credibility arguments	(pro se) Victim’s medication status undermines her credibility; jury should have believed Griffin	Credibility is a jury function; no reversible error shown	Affirmed: credibility and trial strategy issues do not warrant relief

State v. Williams, 525 N.W.2d 538 (Minn. 1994) (sets out fair‑cross‑section prima facie test and comparative/absolute disparity guidance)
State v. Jones, 271 N.W.2d 534 (Minn. 1978) (establishes five‑factor test for admitting prior convictions for impeachment)
State v. Hill, 801 N.W.2d 646 (Minn. 2011) (allows use of unspecified‑felony label when admitting a similar prior conviction under Rule 609)
State v. Roan, 532 N.W.2d 563 (Minn. 1995) (approves jury‑source selection process using voter rolls, driver’s licenses, ID cards)
State v. Swanson, 707 N.W.2d 645 (Minn. 2006) (discusses weighing Jones factors, combining credibility‑related factors)
Hennepin Cnty. v. Perry, 561 N.W.2d 889 (Minn. 1997) (reviews fair‑cross‑section challenges and standards)
State v. Post, 512 N.W.2d 99 (Minn. 1994) (review standard for prejudice when erroneously admitted evidence)
State v. Vance, 734 N.W.2d 650 (Minn. 2007) (plain‑error standard for unobjected‑to jury instructions)