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921 N.W.2d 547
Minn.
2019
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Background

  • Victim David Haiman was killed June 21, 2016; Thoresen was charged with first‑degree premeditated murder and later convicted and sentenced to life without release. His alleged accomplice, Kayleene Greniger, pleaded guilty to second‑degree murder and testified for the State.
  • Greniger testified that she and Thoresen tied, beat, transported, and later killed Haiman (baseball bat, knives, machete), decapitated him, and disposed of the head and body in the woods. She led police to the vicinity of the remains.
  • Multiple witnesses (J.D., J.G., R.G., T.C.) corroborated portions of Greniger’s account: observing injuries, seeing Haiman bound, seeing the maroon car, observing or finding a bat and knives, and hearing admissions by Thoresen. Forensic evidence (blood on machete, knife, car, clothing) tied the scene and items to Haiman; Greniger’s fingerprint was on the machete.
  • Investigators found bloodstains and a machete in the shared apartment; a fillet knife with Haiman’s blood was found in the trunk of Haiman’s car. Thoresen and T.C. were arrested after fleeing in Haiman’s car.
  • Before trial Thoresen requested jury instructions on (1) credibility of drug‑using witnesses and (2) credibility of an uncharged accessory‑after‑the‑fact; the district court denied both but instructed generally on witness credibility.

Issues

Issue Thoresen's Argument State's Argument Held
Whether accomplice testimony (Greniger) was sufficiently corroborated under Minn. Stat. § 634.04 Greniger lied to police/grand jury; corroboration insufficient, and no independent evidence of premeditation Multiple witnesses and forensic evidence corroborated key parts of Greniger’s story and support premeditation Affirmed — corroboration sufficient to uphold conviction
Whether the court abused discretion by refusing instructions on credibility of drug‑using witnesses and of an uncharged accessory‑after‑the‑fact Jury should receive specific instructions warning that drug use/addiction and potential interest as an accessory may impair credibility Court’s general credibility instructions and counsel’s cross‑examination/closing adequately covered these points; specific instructions unnecessary Affirmed — no abuse of discretion; substance of requested instructions was covered by given instructions

Key Cases Cited

  • State v. Rasmussen, 63 N.W.2d 1 (Minn. 1954) (corroboration need only tend in some substantial degree to affirm accomplice testimony)
  • State v. Nelson, 632 N.W.2d 193 (Minn. 2001) (review sufficiency of evidence in light most favorable to prosecution)
  • State v. Sorg, 144 N.W.2d 783 (Minn. 1966) (accomplice testimony considered inherently untrustworthy)
  • State v. Adams, 295 N.W.2d 527 (Minn. 1980) (corroboration may be circumstantial)
  • State v. Scruggs, 421 N.W.2d 707 (Minn. 1988) (corroboration must restore confidence in accomplice testimony)
  • State v. Petersen, 910 N.W.2d 1 (Minn. 2018) (categories of evidence supporting premeditation)
  • State v. Mahkuk, 736 N.W.2d 675 (Minn. 2007) (standard of review for jury‑instruction decisions)
  • State v. Guzman, 892 N.W.2d 801 (Minn. 2017) (abuse of discretion defined for jury instructions)
  • State v. Daniels, 361 N.W.2d 819 (Minn. 1985) (no abuse in denying specific drug‑user instruction where general credibility instructions given)
  • State v. Swanson, 707 N.W.2d 645 (Minn. 2006) (no need to give an instruction when its substance is already included in jury instructions)
  • State v. Yang, 774 N.W.2d 539 (Minn. 2009) (upholding denial of special credibility instructions)
  • State v. LaJambe, 219 N.W.2d 917 (Minn. 1974) (rejecting instruction singling out accomplice testimony as inherently untrustworthy)
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Case Details

Case Name: State v. Thoresen
Court Name: Supreme Court of Minnesota
Date Published: Jan 2, 2019
Citations: 921 N.W.2d 547; A17-1854
Docket Number: A17-1854
Court Abbreviation: Minn.
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