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