State v. Matthews
800 N.W.2d 629
Minn.2011Background
- Audie Matthews was convicted by jury of first-degree murder for the March 8, 2008 shooting death of Blaine Christofferson; life imprisonment imposed.
- Police found a gun, mask, jacket, gloves among other items tied to Matthews; DNA on gun/mask/jacket matched Matthews.
- Security videos show Christofferson interacting with a man in black who shot him; Matthews was present at the Cherry Pit Bar the night of the shooting.
- A police dog tracked a fear scent from the scene to clothing and a handgun later connected to Matthews via DNA; scent tracking ended near Matthews' location.
- Matthews made jailhouse calls admitting something went wrong and mentioning DNA evidence; he did not testify or present witnesses.
- The State argued—at trial—that circumstantial evidence (presence, DNA, footprints, clothing) supported guilt; Moten was excluded as DNA source.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether fear-scent testimony requires reversal | Matthews argues fear-scent evidence was unreliable and prejudicial | Matthews contends admission affected verdict | No reversible error; harmless/plain-error review satisfied |
| Sufficiency of circumstantial-evidence for first-degree murder | Circumstantial evidence insufficient to prove guilt beyond reasonable doubt | Evidence shows guilt beyond reasonable doubt | Sufficient evidence supports conviction |
Key Cases Cited
- State v. Ferguson, 581 N.W.2d 824 (Minn. 1998) (four-factor harmless error test)
- State v. Holliday, 745 N.W.2d 556 (Minn. 2008) (reasonable possibility that wrongfully admitted evidence affected verdict)
- State v. Robinson, 718 N.W.2d 400 (Minn. 2006) (harmless error standard for non-constitutional errors)
- State v. Chiller, 583 N.W.2d 736 (Minn. 1998) (plain-error framework and substantial rights)
- State v. Reed, 737 N.W.2d 572 (Minn. 2007) (connection between plain-error prong and harmless error analysis)
- State v. Goelz, 743 N.W.2d 249 (Minn. 2007) (plain-error principles for preservation and review)
- State v. Strommen, 648 N.W.2d 681 (Minn. 2002) (timeliness of objections governs review standard)
- State v. Andersen, 784 N.W.2d 320 (Minn. 2010) (two-step circumstantial-evidence sufficiency framework)
- State v. Lahue, 585 N.W.2d 785 (Minn. 1998) (avoidance of conjecture; standard for circumstantial sufficiency)
- State v. Curtis, 295 N.W.2d 253 (Minn. 1980) (circumstantial evidence must exclude reasonable hypotheses of innocence)