State v. Hicks, 837 N.W.2d 51

J.R. disappeared in August 2007; police found blood stains in her apartment during welfare check and later at the residence.
Hicks initially denied involvement, surrendered J.R.’s keys and a pair of K-Swiss shoes, and claimed J.R. gave him her keys in April 2007.
DNA and forensic evidence linked Hicks to the scene; the tread on Hicks’s shoes matched bloody prints found in the hallway and blood on his shoes.
J.R.’s remains were discovered in a park years later; Hicks was arrested and charged with second-degree intentional murder and second-degree felony murder.
Hicks waived a jury trial and represented himself at a 12-day bench trial, during which multiple witnesses and forensic experts testified.
The district court sentenced Hicks to 420 months, an upward durational departure based on particular cruelty by concealing the body.

Issue	Plaintiff's Argument	Defendant's Argument	Held
District court’s use of voice-identification evidence	Hicks alleges rule 2.11 violation due to expert/owner’s voice determination.	Court’s own knowledge from proceedings is permissible; no disqualifying personal bias.	No Code violation; impartial-finder standard satisfied.
Right to a public trial during closures	Closures during chambers conferences violated public-trial rights.	Closures were brief, administrative, and agreed to; not prejudicial.	No Sixth Amendment public-trial violation; closures were trivial.
Upward departure for particular cruelty based on body concealment	Concealment alone is insufficient for cruelty-based departure per Leja.	Concealment, combined with murder, supports cruelty-based departure here.	Concealment supported an upward departure; Leja distinguishable on facts.
Concealment as a separate offense justifying departure	Interference with a dead body is a separate offense; cannot support departure.	Offense is not a lesser-included offense; departure permitted.	Concealment not barred as basis for departure; valid here.
Pro se supplemental-brief challenges to evidence and sufficiency	Evidence insufficient; police- statements consistent elements questioned.	Record shows inconsistent statements and corroborating physical evidence; credibility findings supported.	Evidence sufficient; no plain error in admitted materials.

State v. Dorsey, 701 N.W.2d 238 (Minn. 2005) (personal knowledge and disqualification standards for judges)
State v. Pratt, 813 N.W.2d 868 (Minn. 2012) (de novo review of judicial conduct questions)
State v. Burrell, 743 N.W.2d 596 (Minn. 2008) (impartiality and factual-issue review in bench trials)
State v. Mahkuk, 736 N.W.2d 675 (Minn. 2007) (public-trial protections and Waller v. Georgia framework)
State v. Lindsey, 632 N.W.2d 652 (Minn. 2001) (brief courtroom closures evaluated for triviality)
State v. Leja, 684 N.W.2d 442 (Minn. 2004) (concealment alone not always basis for departure; distinguishable facts)
State v. Shiue, 326 N.W.2d 648 (Minn. 1982) (fact pattern supporting particular-cruelty departure due to concealment)
State v. Murr, 443 N.W.2d 833 (Minn. App. 1989) (family impact and cruelty considerations in concealment cases)
State v. Folkers, 581 N.W.2d 321 (Minn. 1998) (particular-cruelty alone can justify upward departure)
State v. Edwards, 774 N.W.2d 596 (Minn. 2009) (substantial and compelling circumstances for departure)
State v. Jones, 745 N.W.2d 845 (Minn. 2008) (不charged or dismissed offenses and departure limitations)
Waller v. Georgia, 467 U.S. 39 (U.S. 1984) (public trial framework and closure justification considerations)