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State v. Moore
2014 Minn. LEXIS 234
| Minn. | 2014
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Background

  • Moore was convicted at trial of first-degree premeditated murder and first-degree domestic-abuse murder, and sentenced to life without release.
  • The State presented evidence of a prolonged lethal stabbing of Mauryn, with a kitchen knife used and many fatal wounds.
  • Moore claimed self-defense; a neighbor testified to a heated argument and a female voice saying Stop.
  • Moore’s former wife testified about Moore’s jealousy and prior abuse; some testimony admitted under residual hearsay rules.
  • The court instructed the jury on premeditation using CRIMJIG 11.02; Moore did not object, but appellate challenges followed.
  • The defenses’ constitutional challenges were raised on appeal but deemed procedurally barred.

Issues

Issue Plaintiff's Argument Defendant's Argument Held
Constitutionality of statute Moore argues § 609.185(a)(1) is vague and unequal. Moore asserts equal protection and vagueness defects distinguishing premeditation from intent. Procedurally barred; court declines review.
Sufficiency of circumstantial evidence for premeditation Evidence established planning, motive, and the manner of killing support premeditation. Challenge to whether inferences support guilt beyond reasonable doubt. Evidence sufficient to support premeditation.
Jury instructions on premeditation timing Instruction adequately conveyed no fixed time requirement and allowed short-term premeditation. Some appreciable time must pass between intent and killing. No error, not plain error.
Admission of former wife’s testimony Testimony admissible to prove domestic abuse pattern and relevance to charges. Testimony about Liberia abuse and other acts may be improper. Minnesota abuse testimony properly admitted; Liberia testimony not shown to affect verdict; harm not substantial.
Residual hearsay testimony Friends’ statements about Mauryn’s complaints admitted under Rule 807. Statements were untrustworthy and uncorroborated; risk of prejudice. Harmless error; no reversal required.

Key Cases Cited

  • State v. Engholm, 290 N.W.2d 780 (Minn. 1980) (statutory challenges cannot be raised for first time on appeal)
  • State v. Schleicher, 672 N.W.2d 550 (Minn. 2003) (procedural bar for unraised constitutional challenges)
  • State v. Goodloe, 718 N.W.2d 413 (Minn. 2006) (premeditation timing instruction consistent with Moore)
  • State v. Anderson, 789 N.W.2d 227 (Minn. 2010) (omission of 'appreciable time' language not error)
  • State v. Merrill, 450 N.W.2d 318 (Minn. 1990) (planning activity supports premeditation; knife retrieval pattern)
  • State v. Hurd, 819 N.W.2d 601 (Minn. 2012) (jealousy evidence supporting motive for premeditation)
  • State v. Moore, 481 N.W.2d 355 (Minn. 1992) (premeditation requires time for deliberation after intent to kill)
  • State v. Palmer, 803 N.W.2d 727 (Minn. 2011) (circumstantial evidence framework for premeditation)
  • State v. Davis, 820 N.W.2d 525 (Minn. 2012) (harmless error assessment for evidentiary rulings)
Read the full case

Case Details

Case Name: State v. Moore
Court Name: Supreme Court of Minnesota
Date Published: May 14, 2014
Citation: 2014 Minn. LEXIS 234
Docket Number: No. A13-0004
Court Abbreviation: Minn.