State v. Hayes, 2013 Minn. LEXIS 307

Background

Hayes convicted of first-degree murder during domestic abuse with a past pattern; also convicted of second-degree murder under a felony murder theory; death of 13-month-old Robert Azure, Jr. while Hayes cared for Robert in TD’s home; medical examiner found multiple head injuries with homicide as cause; defense argued accident via trip over a fan cord; trial court instructed on general standards but not specific past-pattern requirements; verdict and life sentence followed by direct appeal.
Hayes lived with TD and her four children; Robert injured while Hayes was caregiver; siblings testified to Hayes’s anger and prior abuse toward TD; autopsy revealed skull fracture, rib fractures, arm injuries, retinal hemorrhages; physicians concluded injuries were more severe than a simple fall; defense presented expert testimony suggesting accidental mechanism could fit injuries.
State argued evidence supported intentional assault causing death and that past pattern of domestic abuse existed; records showed multiple prior domestic abuse incidents against TD’s other child; medical examiner’s testimony heavily influenced jury; defense challenged the weight and admissibility of expert medical testimony.
The Court held: sufficient evidence supported Hayes’s intentional assault and death; past-pattern proof existed (at least four incidents) and did not require two acts beyond a reasonable doubt as a separate, strictly defined standard; no plain-error in failure to instruct two-act requirement or unanimity on specific acts; Crowsbreast not overruled; affirmed Hayes’s convictions and life sentence.
Concurrence notes potential sufficiency standard ambiguity but agrees affirmance on Part I and III; Dissent argues medical examiner testimony improperly invaded jury’s fact-finding and warrants new trial.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for intent to assault	Hayes argues death could be accidental.	State proved intentional assault beyond reasonable doubt.	Sufficient evidence supports intentional assault and death.
Past pattern requirement evidence	Past pattern not proven for child victims; only four acts against TD; no pattern regarding children.	Past pattern exists with multiple incidents; regularity shown.	Sufficient evidence of past pattern to support 609.185(a)(6).
Jury instruction on two prior acts beyond proof beyond a reasonable doubt	District court should have required two acts beyond a reasonable doubt.	Plain-error analysis shows no error; Hokanson precedent supports current instruction.	No plain error; instruction proper.
Unanimity on which acts prove past pattern	Jury must unanimously agree on specific acts.	Crowsbreast allows non-unanimity for acts; grouping valid.	Jury unanimity not required for past-pattern acts.

Key Cases Cited

State v. Holliday, 745 N.W.2d 556 (Minn.2008) (sufficiency review framework; view most favorable to verdict)
State v. Leake, 699 N.W.2d 312 (Minn.2005) (guilt beyond a reasonable doubt standard)
State v. Andersen, 784 N.W.2d 320 (Minn.2010) (circumstantial evidence inference framework)
State v. Al-Naseer, 788 N.W.2d 469 (Minn.2010) (two-step analysis for circumstantial evidence sufficiency)
State v. McArthur, 730 N.W.2d 44 (Minn.2007) (circumstantial inference to guilt)
State v. Hokanson, 821 N.W.2d 340 (Minn.2012) (reaffirmed fair instructions when past-pattern proven beyond proving two acts)
State v. Crowsbreast, 629 N.W.2d 433 (Minn.2001) (no required jury unanimity on which acts constitute past pattern)
State v. Johnson, 773 N.W.2d 81 (Minn.2009) (definition of past pattern requires more than a lone act)
State v. Her, 750 N.W.2d 258 (Minn.2008) (pattern of abuse is a fact-intensive inquiry)
State v. Beecroft, 813 N.W.2d 831 (Minn.2012) (role and independence of medical examiners)
State v. Saldana, 324 N.W.2d 227 (Minn.1982) (expert testimony and helpfulness standard)