State v. Palmer, 2011 Minn. LEXIS 608

Palmer was convicted after a five-day bench trial of first-degree premeditated murder, second-degree intentional murder, and firearm possession; he received life without release for the first-degree murder conviction.
The shooting occurred during a debt-collection dispute involving Moss, Palmer, and Palmer’s brother Da’Leino Palmer, who had previously supplied Moss with crack cocaine.
Palmer loaded and prepared the handgun, allegedly wiping fingerprints from cartridges, and kept the gun accessible prior to the shooting.
The shooting happened in Moss’s residence after a heated confrontation; Palmer paused between shots and then finished Moss off while Moss was on or near the ground.
The State’s theory rested on circumstantial evidence of planning, motive, and the nature of the killing; Palmer argued the act was rash and unpremeditated.
On appeal, Palmer asserted insufficiency of evidence for premeditation and raised pro se claims about lesser offenses, sentencing pronouncements, and ineffective assistance, all of which the court rejected.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence for premeditation	Palmer argues evidence does not prove premeditation beyond reasonable doubt.	State contends circumstantial evidence supports planning, motive, and nature of killing.	Evidence supports premeditation beyond reasonable doubt.
Duty to consider lesser-included manslaughter offenses	Palmer claims district court should have sua sponte consider heat-of-passion/culpable-negligence manslaughter.	State says failure to raise waived claim; plain-error review applies if necessary.	No reversible plain error; omission did not affect substantial rights.
Sentencing pronouncement	Palmer contends the court improperly pronounced his sentence.	State argues statute did not require additional minimum/maximum terms given life sentence without release.	Sentence pronouncement was proper.
Ineffective assistance of trial counsel claims	Palmer asserts counsel failed to file or pursue appeal/adequate speedy-trial rights.	State argues claims were waived or lack supporting argument.	Claims waived; no plain prejudice shown.

State v. Holliday, 745 N.W.2d 556 (Minn. 2008) (premeditation evidence categories; motive and nature of killing)
State v. Leake, 699 N.W.2d 312 (Minn. 2005) (two-step approach to circumstantial-evidence review)
State v. Anderson, 789 N.W.2d 227 (Minn. 2010) (circumstantial-inference analysis and deference to finder’s credibility)
State v. Moore, 481 N.W.2d 355 (Minn. 1992) (premeditation requires some appreciable time after intent to kill)
State v. Yang, 774 N.W.2d 539 (Minn. 2009) (short interval between acts can support premeditation)
State v. Clark, 739 N.W.2d 412 (Minn. 2007) (premeditation shown by deliberate, planned shooting; multiple wounds)
State v. Austin, 332 N.W.2d 21 (Minn. 1983) (premeditation can occur in a short time frame after forming intent)