State v. Ortega, 2012 Minn. LEXIS 150

Troy Ulrich was stabbed to death in a garage in Claremont, Minnesota on February 16, 2008, during an altercation with Ortega and his family.
Ortega and family members pursued Ulrich in the garage, culminating in multiple stab wounds, with evidence of planning-like conduct and escape efforts after the killing.
Forensic and witness evidence showed the fight moved within the garage, culminating in Ulrich's death near a corner of the garage; eight stab wounds were to the chest/midsection.
Ortega admitted in a post-arrest interview that he stabbed Ulrich in self-defense after Ulrich attacked him; he disposed of evidence and attempted to hide the knife.
Ortega moved for suppression of statements made to investigators, arguing violations of right to counsel and improper reinitiation; the district court denied suppression and the State presented excerpts at trial.
A jury convicted Ortega of four counts, including first-degree premeditated murder; the district court sentenced him to life without parole; Ortega appealed raising suppression, voir dire, and sufficiency claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was there proper reinitiation after invoking counsel?	Ortega argues investigators coerced waiver and used improper reinitiation.	Ortega contends reinitiation occurred via investigators' statements and violated rights.	No reversible error; Ortega reinitiated and valid waiver occurred.
Did Gunderson stop and clarify an equivocal request for counsel?	Ortega argues the request was equivocal and not adequately handled.	Gunderson properly clarified and continued questioning within lawful limits.	District court did not err; stop-and-clarify satisfied.
Was the State’s voir dire question about valuing human life harmless error?	Ortega seeks new trial for voir dire question biasing jurors.	State asserts harmless error and relevance to self-defense case.	Harmless; no new trial needed.
Is the evidence sufficient to sustain a conviction for first-degree premeditated murder?	Ortega claims insufficient circumstantial evidence of premeditation.	State argues planning, motive, and nature of killing prove premeditation.	Evidence sufficient to sustain conviction.

Edwards v. Arizona, 451 U.S. 477 (U.S. 1981) (right to counsel; interrogation must stop after invocation unless suspect initiates further communication)
Bradshaw, 462 U.S. 1039 (U.S. 1983) (reinitiation depends on suspect's general discussion about investigation)
State v. Staats, 658 N.W.2d 207 (Minn. 2003) (distinguish routine custodial questions from reinitiation concerns)
State v. Miller, 573 N.W.2d 661 (Minn. 1998) (clarification of rights does not constitute reinitiation)
State v. Robinson, 427 N.W.2d 217 (Minn. 1988) (stop-and-clarify rule for equivocal requests for counsel)
State v. Earl, 702 N.W.2d 711 (Minn. 2005) (totality of circumstances in reinitiation analysis)
State v. Palmer, 803 N.W.2d 727 (Minn. 2011) (premeditation can occur in short time frames; consider timing of killings)
State v. Yang, 774 N.W.2d 539 (Minn. 2009) (three-category framework: planning, motive, nature of killing)
State v. Anderson, 789 N.W.2d 227 (Minn. 2010) (circumstances proved; standard for circumstantial evidence sufficiency)