State v. Watkins
2013 Minn. LEXIS 742
| Minn. | 2013Background
- DANCO issued restricting Watkins from contacting his girlfriend; DANCO misspelled name and birth date but identified protected person.
- Watkins allegedly contacted the girlfriend on Oct. 30, 2010, by phone, and Feb. 2011, via a card.
- Watkins charged with two felony DANCO violations under Minn.Stat. § 629.75, subd. 2(d)(1).
- Jury convicted Watkins; district court imposed 44 months and a 5-year DANCO.
- Court of Appeals reversed, citing failure to instruct on the “knowingly” element as plain error affecting substantial rights.
- Supreme Court held the omission was trial error and remanded for new trial on different grounds; statute later amended removing “knowingly.”
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether omission of the knowingly element is structural or trial error | Watkins (State) argues structural error. | Watkins contends structural error affects trial integrity. | Omission reviewed as trial error (not structural). |
| Whether plain-error analysis applies to unobjected jury instruction | State concedes error was plain; asks plain-error standard. | Watkins argues plain-error analysis governs prejudice to substantial rights. | Plain-error analysis applies; must show error, plainness, and substantial-rights impact. |
| What the meaning of 'knowingly violates' is in Minn.Stat. § 629.75, subd. 2(d) | State argues knowledge of the DANCO’s existence is enough. | Watkins argues no subjective knowledge required; factual knowledge suffices. | 'Knowingly violates' requires perception that conduct violated the DANCO; subjective knowledge not required to establish offense. |
| Did the omission prejudicially affect Watkins' substantial rights | State contends record supports conviction without the element. | Watkins asserts prejudice if element omitted; defense contested knowledge element. | Omission prejudicial; Watkins’ defense on knowledge could have influenced verdict; new trial required. |
| Should a new trial be ordered given the prejudice | State argues no automatic new trial; harmless-error standards apply. | Watkins argues prejudice warrants new trial to preserve fairness. | New trial required to safeguard fairness and integrity of judicial proceedings. |
Key Cases Cited
- Neder v. United States, 527 U.S. 1 (U.S. 1999) (omission of an element analyzed under harmless error rather than structural error)
- State v. Milton, 821 N.W.2d 789 (Minn. 2012) (omission of an element reviewed under harmless-error framework)
- State v. Mahkuk, 736 N.W.2d 675 (Minn. 2007) (reaffirmed that omission does not automatically require a new trial)
- State v. Hall, 722 N.W.2d 472 (Minn. 2006) (premeditation-focused omission case; not automatically prejudicial)
- State v. Colvin, 645 N.W.2d 449 (Minn. 2002) (addressed knowledge requirement in OFP/DANCO contexts; supports knowledge interpretation)