State v. Hayes
2013 Minn. LEXIS 111
| Minn. | 2013Background
- Hayes was convicted of first-degree felony murder while committing a drive-by shooting and second-degree intentional murder; the district court sentenced him to life with possibility of release and later the conviction on the felony-murder count was reversed; the State alleged drive-by shooting as the predicate offense and introduced eyewitness testimony including T.S.’s identification of Hayes and observations of the shooting; DeRonde died from a single gunshot wound consistent with a near-shot distance; police stops and interviews tied Hayes to the red Dodge Intrepid with co‑defendant Funches; Funches initially gave one version of events and later provided another in which Hayes allegedly fired after DeRonde failed to pay for marijuana; the jury found Hayes not guilty of first-degree premeditated murder, guilty of first-degree felony murder while committing a drive-by shooting, and guilty of second-degree intentional murder, but the district court adjudicated only the felony-murder count.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the State proved drive-by shooting as the predicate offense | Hayes—insufficient to show firing at or toward a building/vehicle | State ambiguous interpretation of drive-by statute supports conviction | Conviction reversed for failure to prove drive-by shooting element |
| Statutory interpretation of Minn. Stat. § 609.66, subd. 1(b) | State argues separate offense via ‘by’; supports felony-murder premise | Hayes argues § 609.66(1)(b) is a sentence enhancement | Better interpretation is sentence enhancement applicable when drive-by shooting occurred |
| Admissibility of witness fear/threat evidence about Funches | Evidence relevant to credibility and motives; preempts defense attacks | Testimony unfairly prejudicial; should be limited | Admissible; not plain error; no need to remand for cautionary instruction |
Key Cases Cited
- State v. Leathers, 799 N.W.2d 606 (Minn. 2011) (statutory interpretation; ambiguity analysis of drive-by shooting statute)
- Premier Bank v. Becker Dev., LLC, 785 N.W.2d 753 (Minn. 2010) (plain and ordinary meaning; ambiguity canons)
- Larson v. State, 790 N.W.2d 700 (Minn. 2010) (plain meaning of statutes; ambiguity considerations)
- State v. McArthur, 730 N.W.2d 44 (Minn. 2007) (admissibility of fear/credibility evidence; trial safeguards)
- State v. Hill, 801 N.W.2d 646 (Minn. 2011) (plain-error review framework)
- State v. Griller, 583 N.W.2d 736 (Minn. 1998) (prejudice vs probative value; weighting of evidence)
- State v. Pilot, 595 N.W.2d 511 (Minn. 1999) (plain-error analysis; procedural guidance)
- State v. Vance, 714 N.W.2d 428 (Minn. 2006) (need for cautionary instruction; not automatic error)
- State v. Forsman, 260 N.W.2d 160 (Minn. 1977) (statutory interpretation limitations; legislative definitions)