State v. Hill, 801 N.W.2d 646

Hill was convicted by jury of first-degree premeditated murder for shooting Jeffrey Logan outside the American Legion club; district court sentenced him to life imprisonment without the possibility of release.
Prosecution presented eyewitnesses and forensic evidence linking Hill to the shooting; firearms recovered included a Beretta and a Sig Sauer; Hill’s DNA matched samples on the firearms.
Hill testified in his defense alleging self-defense; the defense version conflicted with eyewitness and forensic evidence.
The district court allowed impeachment of Hill with evidence of an unspecified felony conviction (2008 Illinois robbery) under Rule 609(a) and gave a limiting instruction.
The State elicited testimony that Hill’s DNA was obtained via a search warrant while others’ DNA samples were volunteered; Hill did not object.
Evidence about a home invasion and the theft of a Beretta was admitted to show history and status of the gun; the court issued a limiting instruction but defense requested strike; Hill objected to trial.
The court ultimately affirmed Hill’s conviction on all counts.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Impeachment with an unspecified felony conviction	Hill argues admission was an abuse of discretion	Hill contends unspecified felony undermined credibility appropriately	Not reversible; district court properly weighed Rule 609(a) factors and allowed unspecified conviction
Prosecutorial misconduct regarding DNA sampling	Hill claims testimony implied he hid from testing due to guilt	State argues no due process violation; minimal impact	No reversible error; evidence did not affect substantial rights; at most harmless or plain error in context handled as harmless
Admission of evidence about the stolen Beretta and home invasion	Hill contends Spreigl and relevance issues; prejudicial	State asserts admissible to explain history and status of the gun	Harmless error; strong evidence against Hill; limiting instruction and lack of prosecutorial focus on this detail
Cumulative error claim	Cumulative effects denied fair trial	No reversible error individually or cumulatively	No due process violation; no reversible error given the record and evidence against Hill

State v. Ihnot, 575 N.W.2d 581 (Minn. 1998) (impeachment of witnesses by prior convictions; abuse of discretion standard)
State v. Jones, 271 N.W.2d 534 (Minn. 1978) (five-factor Rule 609(a) analysis guidance)
State v. Riddley, 776 N.W.2d 419 (Minn. 2009) (harmless error assessment and cautionary instructions)
State v. Prtine, 784 N.W.2d 303 (Minn. 2010) (prosecutorial misconduct without substantial rights impact preservations)
State v. Courtney, 696 N.W.2d 73 (Minn. 2005) (harmless error when misconduct not dwelled upon in closing)