State v. Scruggs, 2012 Minn. LEXIS 528

Scruggs was convicted by a Hennepin County jury of first-degree premeditated murder and second-degree intentional murder for Fonta's February 4, 2010 death; he received life imprisonment without release on the first-degree murder conviction.
Police interviewed Scruggs and H.J. at Fonta's apartment and later at the police station; H.J. was detained on a misdemeanor trespass warrant, while Scruggs was released after his interview.
Forensic evidence included Fonta's strangulation, multiple injuries, Fonta's DNA on a cord, and blood found in Fonta's apartment; shell and fabrics linked to Fonta were found disposed of nearby.
H.J. initially denied knowledge, then confessed to watching Scruggs kill Fonta and to helping conceal the evidence; M.P. testified that Scruggs admitted beating and strangling someone and removing a hair braid.
The district court admitted Scruggs’s police statement without a Miranda warning, rejected his custody arguments, allowed limited Spreigl evidence of Scruggs’s prior assaults on H.J., and the jury returned guilty verdicts; on direct appeal, Scruggs challenges Miranda, accomplice instructions, aiding-and-advising theory, Spreigl evidence, and pro se issues, all of which the court affirms in full.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Miranda custody and admissibility of statement	Scruggs argues he was in custody and lacked a Miranda warning	State contends he was not in custody under the circumstances	Not in custody; statement properly admitted
H.J. as accomplice as a matter of law	H.J. was an accomplice as a matter of law based on presence and conduct	Accomplice status is a factual question for the jury	H.J. was not an accomplice as a matter of law; jury question remains
Accomplice instruction—aiding-and-advising theory	Should have instructed aiding-and-advising liability beyond CRIMJIG 3.18	Instruction on corroboration suffices; aiding-and-advising not essential	Not plain error to omit aiding-and-advising instruction; no reversal
Admission of Spreigl evidence (prior assaults)	Evidence admissible to explain H.J.'s fear and inconsistent statements	Potential prejudice; probative value limited	Properly admitted with limiting instructions; not reversible error
Pro se arguments and other challenges	State knowingly presented perjury and various trial errors	Credibility and procedure issues warrant relief	Arguments meritless; affirmance warranted

Oregon v. Mathiason, 429 U.S. 492 (U.S. 1977) ( Miranda warning requirements depend on custody and interrogation)
State v. Thompson, 788 N.W.2d 485 (Minn. 2010) ( custody test for Miranda in Minnesota)
State v. Vue, 797 N.W.2d 5 (Minn. 2011) ( custody factors; noncustodial interview circumstances)
State v. Wiemasz, 584 N.W.2d 1 (Minn. 1998) ( independent custody determinations; deference to district findings)
State v. Barrientos-Quintana, 787 N.W.2d 603 (Minn. 2010) ( accomplice status and corroboration guidance)
State v. Parker, 282 Minn. 343, 164 N.W.2d 633 (Minn. 1969) ( delineates knowing presence as aiding, not mere presence)
State v. Shoop, 441 N.W.2d 475 (Minn. 1989) ( requirement to instruct on accomplice testimony )
State v. Williams, 418 N.W.2d 163 (Minn. 1988) ( corroboration and accomplice testimony guidance)
State v. McArthur, 730 N.W.2d 44 (Minn. 2007) ( rehabilitation and timing of credibility evidence)
State v. Loving, 775 N.W.2d 872 (Minn. 2009) ( 404(b) probative value and prejudice balancing)
State v. Fardan, 773 N.W.2d 303 (Minn. 2009) ( 404(b) notice and balancing framework)
State v. Ness, 707 N.W.2d 676 (Minn. 2006) ( prejudice concerns with Spreigl evidence)