State v. Thomas, 891 N.W.2d 612

Police found Thomas asleep in a running pickup at ~4 a.m.; field sobriety tests failed and a breath test showed .16 BAC; State charged him with gross misdemeanor second-degree DWI based on two prior impaired-driving incidents.
Pretrial, defense counsel warned Thomas and reviewed certified records of a 2007 Minnesota loss of license and a 2006 Wisconsin OUI; the State pre-marked those certified copies as exhibits but did not offer them during its initial case-in-chief.
After the State rested, Thomas moved for judgment of acquittal for insufficiency of the evidence (arguing the State had not proved the prior incidents). The prosecutor then sought to reopen the State’s case to introduce the certified prior-record exhibits.
The district court granted the State’s motion to reopen before ruling on Thomas’ motion for acquittal, received the certified copies (without defense objection), denied the acquittal motion, and the jury found Thomas guilty.
The court of appeals affirmed; the Minnesota Supreme Court granted review to decide (1) whether the court was required to rule on the acquittal motion before considering a motion to reopen, and (2) whether permitting the State to reopen was an abuse of discretion.

Issue	Thomas' Argument	State's Argument	Held
Whether Minn. R. Crim. P. 26.03, subd. 18(2) required the court to rule immediately on a motion for judgment of acquittal made at the close of the State’s case before addressing the State’s motion to reopen.	The court "must rule" immediately on the acquittal motion and therefore could not consider the State’s reopen motion first.	The rule requires the court to rule on the acquittal motion before advancing the trial stage, but it does not forbid the court from first deciding whether to allow the State to reopen its case.	The court may consider a motion to reopen before ruling; the rule does not require ruling on the acquittal motion prior to deciding a reopen request.
Whether the district court abused its discretion in allowing the State to reopen its case-in-chief in response to Thomas’ acquittal motion.	Allowing reopening after the defendant points out an evidentiary gap (per State v. Allen) is an abuse because it penalizes defendants who diligently identify insufficiencies.	Rule 26.03(g) gives broad discretion; Caine factors control (timing, materiality, improper purpose), and where the omitted evidence is material, known, readily available, and produced without improper purpose, reopening is proper.	No abuse of discretion. Applying Caine factors, reopening was timely, the prior-offense records were material and not cumulative, Thomas had notice and was not prejudiced, and the omission was inadvertent.

State v. Slaughter, 691 N.W.2d 70 (Minn. 2005) (protects defendant from being forced to present evidence that fills gaps in prosecution’s case; prohibits reserving ruling on acquittal made at close of prosecution’s case)
State v. Caine, 746 N.W.2d 339 (Minn. 2008) (sets guiding factors for reopening a case: timing, materiality/noncumulativeness/controlling-issue, and improper purpose)
State v. Berg, 326 N.W.2d 14 (Minn. 1982) (recognizes trial court discretion to allow prosecutor to reopen case-in-chief)
State v. Penkaty, 708 N.W.2d 185 (Minn. 2006) (discusses promptness in ruling on acquittal motions)
State v. Blom, 682 N.W.2d 578 (Minn. 2004) (recognizes broad trial-court discretion in managing trials)
State v. Jouppis, 179 N.W. 678 (Minn. 1920) (early recognition that reopening rests in trial court discretion)
State v. Allen, 533 A.2d 559 (Conn. 1987) (articulates rule that reopening after defendant’s acquittal motion identifying a gap is an abuse of discretion; discussed and declined here)