State v. Munt
2013 Minn. LEXIS 311
| Minn. | 2013Background
- Indicted with 17 counts including first-degree murder, aggravated robbery, kidnapping, assault, and criminal vehicular operation; bifurcated trial due to mental-illness defense.
- Munt claimed not guilty and not guilty by reason of mental illness; phase one established guilt on all counts, phase two addressed mental illness.
- Munt’s custody fight and domestic disputes preceded the shooting; murder occurred during a scheduled visitation.
- Park shooting and car crash left Svetlana dead; children injured, seized by Munt, and taken in a stolen vehicle.
- Trial court encountered a challenged juror (B.S.) whose voir dire suggested bias against the mental-illness defense; majority affirmed ruling, dissent argued bias existed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court erred in denying removal for cause of juror B.S. | Munt; B.S. showed actual bias against defense. | State; B.S. not biased when viewed in context. | No abuse of discretion; B.S. lacked actual bias. |
| Whether the trial court’s scheduling comments biased the jury | Comments indicated the court’s belief in guilt. | Comments merely conveyed scheduling and were not prejudicial. | Not reversible error; no bias or coercion detected. |
| Whether the trial court erred by excluding surrebuttal testimony | Surrebuttal would rebut car-seat evidence of premeditation. | Evidence was cumulative and harmless beyond a reasonable doubt. | Harmless error; verdict upheld. |
| Whether the 9-year-old daughter’s competency to testify was incorrectly determined | Competency determination deprived defense of a complete defense. | Court properly found lack of ability to relate truthful facts. | Not an abuse of discretion; child not competent. |
| Whether the district court failed to inquire into pretrial complaints about counsel | Exceptional circumstances existed; need for substitute counsel. | No exceptional circumstances; counsel acceptable and proceedings continued. | No remand; court acted within discretion. |
Key Cases Cited
- Irvin v. Dowd, 366 U.S. 717 (U.S. 1961) (impartial-jury right; bias requires removal)
- Patton v. Yount, 467 U.S. 1025 (U.S. 1984) (deference to trial judge on impartiality; demeanor matters)
- Skilling v. United States, 130 S. Ct. 2896 (S. Ct. 2010) (high deference to judge’s impartiality determinations)
- McKenzie v. State, 583 N.W.2d 744 (Minn. 1998) (presumption of proper judicial duty; anonymous jury context)
- State v. Nissalke, 801 N.W.2d 82 (Minn. 2011) (rehabilitation standards for biased jurors)
- Pratt v. State, 813 N.W.2d 868 (Minn. 2012) (impartial-judge considerations; structural error context)
- Schlienz v. State, 774 N.W.2d 361 (Minn. 2009) (impartial-judge and ex parte considerations)
- Dorsey v. State, 701 N.W.2d 238 (Minn. 2005) (judge as fact-finder; impartiality concerns)
- Powell v. Anderson, 660 N.W.2d 107 (Minn. 2003) (Liljeberg framework; judge impartiality)