State v. McDonald-Richards
2013 Minn. LEXIS 211
| Minn. | 2013Background
- McDonald-Richards was convicted of aiding and abetting first-degree murder and attempted first-degree murder arising from a robbery and shooting at Avi's Pawn & Jewelry on September 28, 2009.
- Police arrested McDonald-Richards during a traffic stop the following day without probable cause, and she was held in custody before interrogation.
- Two police interviews were conducted in which McDonald-Richards admitted various facts; she later claimed fear and that she had lied in the first interview.
- The State introduced both statements at trial; McDonald-Richards moved to suppress the September 29 statement as fruit of an unlawful arrest, which the district court denied.
- The jury found McDonald-Richards guilty on both counts; the sentence imposed ran concurrently.
- On direct appeal, McDonald-Richards contends the first statement was incorrectly admitted; the court agrees the admission was error but finds the error harmless beyond a reasonable doubt.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was the September 29, 2009, statement admissible after an unlawful arrest? | McDonald-Richards | McDonald-Richards | Admission improper; taint not purged |
| Was the erroneous admission of the September 29 statement harmless beyond a reasonable doubt? | McDonald-Richards | McDonald-Richards | Harmless beyond a reasonable doubt |
Key Cases Cited
- Brown v. Illinois, 422 U.S. 590 (U.S. 1975) (taint of illegal arrest not purged by Miranda alone; factors apply)
- Wong Sun v. United States, 371 U.S. 471 (U.S. 1963) (fruit-of-the-poisonous-tree doctrine and attenuation factors)
- Weekes I, 312 Minn. 1 (Minn. 1977) (Brown-based framework for taint analysis in Minnesota)
- Weekes II, 268 N.W.2d 705 (Minn. 1978) (non-dispositive factors; no single factor controls taint purging)
- Taylor v. Alabama, 457 U.S. 687 (U.S. 1982) (intervals between illegal seizure and confession; intervening events)
- Dunaway v. New York, 442 U.S. 200 (U.S. 1979) (voluntariness vs. Fourth Amendment taint; separate inquiries)
- Olson, 436 N.W.2d 92 (Minn. 1989) (confinement timing and taint considerations under Minnesota law)
- Wilson, 535 N.W.2d 597 (Minn. 1995) (Fifth Amendment voluntariness factors in Minnesota context)
- Jungbauer, 348 N.W.2d 344 (Minn. 1984) (brief police questioning and voluntariness considerations)
- Munson, 594 N.W.2d 128 (Minn. 1999) (objective probable cause standard for arrest context)
- State v. Larson, 788 N.W.2d 25 (Minn. 2010) (harmless-error framework for evidentiary errors)