State v. Seaver, 820 N.W.2d 627

Defendant Brittany Seaver was convicted of aiding and abetting first-degree burglary, second-degree assault, and attempted first-degree aggravated robbery.
The state challenged Seaver’s first four peremptory strikes as gender-based Batson challenges against male jurors B, H, M, and V.
District court sustained the state’s gender-based Batson challenges to strikes of H and M and denied challenges to B and V.
Stene and Agee were accomplices who testified during trial; Seaver did not receive an accomplice-testimony jury instruction.
The district court precluded testimony that Seaver was afraid for her children’s safety, limiting her duress defense claim.
On appeal, Seaver argues Batson error, lack of accomplice instruction, restriction of testimony on fear for children, and an upward-durational-departure sentence; the court reverses and remands for a new trial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was there clear Batson error in sustaining the gender-based challenges to H and M?	Seaver	State	Yes; district court clearly erred; remand for new trial.
Was an accomplice-testimony jury instruction required?	Stene and Agee were accomplices	Instruction unnecessary without request	Yes; instruction required on remand if Stene or Agee testifies.
Did the trial court improperly limit testimony about fear for children’s safety?	Seaver should be allowed to explain motivation	Evidence irrelevant/prejudicial	Yes; remand instruction to permit such testimony.
Were issues regarding an upward-durational-departure sentence addressed?			Not central to Batson reversal; opinion focuses on Batson remand.

J.E.B. v. Alabama, 511 U.S. 127 (1994) (gender cannot be used as a proxy for bias in juror strikes)
Carridine v. State, 812 N.W.2d 130 (Minn. 2012) (three-step Batson test; burden-shifting analysis)
Pendleton, 725 N.W.2d 717 (Minn. 2007) (Batson procedure must be followed at each step)
Reiners, 664 N.W.2d 826 (Minn. 2003) (clarity required in Batson analysis steps)