State v. Hurd, 819 N.W.2d 591

Hurd was indicted in Steele County on one count of first-degree premeditated murder, one count of first-degree murder while committing a kidnapping, one count of second-degree intentional murder, and two counts of second-degree felony murder, relating to Kathryn Anderson’s stabbing death.
A jury convicted Hurd on all counts; the trial court sentenced him to life in prison without the possibility of parole for first-degree premeditated murder.
Hurd challenged the conviction on insufficient evidence of premeditation, insufficient evidence of kidnapping, and a proposed jury instruction ruling that incidental confinement/removal cannot support kidnapping.
The appellate court affirmed the first-degree premeditated murder conviction, and indicated it would not reach the unresolved kidnapping-related and instruction arguments because Hurd was only convicted of premeditated murder on appeal.
The defense conceded intentional killing but argued no kidnapping or premeditation; the State’s circumstantial evidence was evaluated for sufficiency under a two-step framework for premeditation.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for premeditated murder	State argues circumstantial evidence supports premeditation	Hurd contends evidence does not unerringly point to premeditation	Evidence sufficient for premeditation
Sufficiency of evidence for first-degree murder while committing kidnapping	State contends counts support kidnapping-based murder	Hurd argues insufficient kidnapping evidence	Not reached; conviction upheld on premeditated murder; kidnapping issue left for another proceeding
Instruction on confinement/removal incidental to murder	State asserts no error in jury instruction handling	Hurd seeks instruction limiting kidnapping to non-incidental confinement	Not reached; not necessary to address due to conviction scope

State v. Fleck, 777 N.W.2d 233 (Minn.2010) (sufficiency review standard for circumstantial evidence)
State v. Leake, 699 N.W.2d 312 (Minn.2005) (credibility and weight for jury findings)
State v. Andersen, 784 N.W.2d 320 (Minn.2010) (two-step analysis for circumstantial evidence // inferencing from circumstances)
State v. Moore, 481 N.W.2d 355 (Minn.1992) (premeditation shown by time for planning after intent to kill)
State v. Moua, 678 N.W.2d 29 (Minn.2004) (motive and planning as part of premeditation analysis)
State v. Voorhees, 596 N.W.2d 241 (Minn.1999) (planning and concealment aspects supporting premeditation)