State v. Sterling, 834 N.W.2d 162

Background

Victim Leo Kohorst was beaten to death in his Minneapolis house on Oct. 16–17, 2010; four tenants lived there, including appellant Adam Sterling.
Police transported Sterling and two housemates to the Homicide Unit for questioning; Sterling was interviewed off and on for ~11 hours and was Mirandized only about 9.5 hours into questioning, at which point he was arrested.
Physical evidence: Sterling’s high-heeled sandals recovered from his room had Kohorst’s blood spatter on the tops but not on the insoles; blood matching Kohorst was on Sterling’s left hand and on a shower curtain; a claw hammer like the missing tool produced puncture wounds consistent with the fatal blows.
Boatwright testified he heard sounds (including high heels) and later found Sterling near Kohorst’s blood-covered body; some of Sterling’s clothing worn earlier that day was missing and never recovered.
Sterling moved to suppress pre-Miranda statements (arguing he was in custody) and challenged sufficiency of circumstantial evidence; the trial court suppressed post-Miranda statements after an asserted invocation of counsel but admitted pre-Miranda statements; Sterling was convicted of first-degree premeditated murder and second-degree murder and sentenced to life without release.

Issues

Issue	Sterling's Argument	State's Argument	Held
Whether pre-Miranda statements should be suppressed because Sterling was "in custody"	He was effectively in custody at the Homicide Unit (secure facility, guarded room, denied requests to leave), so statements before Miranda should be suppressed	Transportation was voluntary; he was not arrested, not restrained, not told he was a suspect; environment and conduct did not make interrogation custodial	Court held not in custody before 10:11 a.m.; pre-10:11 statements admissible; later period close but any error admitting post-10:11 statements was harmless beyond a reasonable doubt
Whether police honored Sterling’s invocation of counsel after Miranda	Miranda invocation was unambiguous and police continued questioning	Court had already found statements after Miranda should be suppressed at trial for failed invocation	Trial court suppressed post-Miranda statements for failure to honor request; appellate court affirmed that suppression as to post-Miranda statements but found admission error (if any) harmless
Sufficiency of circumstantial evidence to support murder conviction	Evidence is circumstantial and lacks direct proof tying Sterling to the killing; conviction should be overturned	Blood on Sterling’s heels, blood on his hand, timeline, missing clothes/hammer, and witness testimony support guilt beyond a reasonable doubt	Court held the circumstantial evidence, viewed as a whole, was sufficient and inconsistent with reasonable alternative hypotheses
Whether an intruder or another tenant (Boatwright) was a reasonable alternative hypothesis	Alternative perpetrators argued plausible (eg, intruder or Boatwright)	State: no forced entry, no motive or physical link to Boatwright, blood evidence points to Sterling	Court rejected alternative hypotheses as unreasonable given the proved circumstances and inferences pointing to Sterling

Key Cases Cited

Thompson v. Keohane, 516 U.S. 99 (legal standard: custody is mixed question of law and fact)
State v. Wiernasz, 584 N.W.2d 1 (Minn. 1998) (appellate review framework for custody findings)
State v. Staats, 658 N.W.2d 207 (Minn. 2003) (custody factors guidance)
State v. Champion, 533 N.W.2d 40 (Minn. 1995) (custody/Miranda context)
State v. Vue, 797 N.W.2d 5 (Minn. 2011) (custody factors list)
Thompson v. State, 788 N.W.2d 485 (Minn. 2010) (Miranda custodial interrogation rule applied)
State v. Juarez, 572 N.W.2d 286 (Minn. 1997) (harmless-error/impact analysis)
State v. Al-Naseer, 690 N.W.2d 744 (Minn. 2005) (factors in harmless-error review)
State v. Andersen, 784 N.W.2d 320 (Minn. 2010) (two-step circumstantial-evidence sufficiency test)
State v. Palmer, 803 N.W.2d 727 (Minn. 2011) (standard: consistent with guilt and inconsistent with any rational hypothesis except guilt)