State v. Webster, 894 N.W.2d 782

Victim Eulalio Gonzalez-Sanchez was found shot to death on a Minneapolis sidewalk on Sept. 21, 2014; wallet remained at scene, phone was missing.
Surveillance showed a car leaving the scene; police later stopped Jeremiah Blackwell in a similar car and found a .40-caliber handgun forensically consistent with the murder weapon.
Cell-tower data placed Blackwell’s phone near the murder scene that morning. Blackwell identified Montrell Webster to police.
Webster initially denied involvement, then confessed to robbing and shooting the victim while preparing to testify; he later recanted and gave alternative suspect names.
At trial Webster conceded the facts could establish felony murder but argued his killing was caused by a sudden, unexplained impulse and challenged jury instructions; jury convicted him of first-degree felony murder (aggravated robbery theory) and he was sentenced to life with parole eligibility after 30 years.

Issue	Webster's Argument	State's Argument	Held
Sufficiency of evidence that killing occurred "while" attempting aggravated robbery	Killing resulted from an independent, irresistible impulse (no causal link to robbery)	Murder and attempted robbery were part of one continuous transaction; robbery continued after shooting	Evidence sufficient; conviction affirmed
Jury instruction omission of explicit causal-relationship language	Instruction should have required jurors to find causal relationship between robbery and killing	Standard jury instruction wording was sufficient; no controlling authority required added language	No plain error; instruction not plainly erroneous; affirmed

Bellcourt v. State, 390 N.W.2d 269 (discusses "while" as part of a continuous transaction for felony murder)
State v. Russell, 503 N.W.2d 110 (felony-murder may apply if fatal wound inflicted during the chain of events linking felony and killing)
State v. Heden, 719 N.W.2d 689 (upholding felony-murder where assault intended to stop resistance led to death)
State v. Milton, 821 N.W.2d 789 (failure to give a requested specific explanatory instruction was not plain error where law did not clearly require it)
State v. Lilienthal, 889 N.W.2d 780 (plain-error framework for considering unobjected-to jury instructions)
State v. Ramey, 721 N.W.2d 294 (definition of "plain" or "obvious" error)
State v. Darris, 648 N.W.2d 232 (standard for reviewing sufficiency of evidence)
State v. Brown, 815 N.W.2d 609 (allocation rule: if one plain-error requirement fails, need not address others)
State v. Kelley, 855 N.W.2d 269 (plain-error assessed against law existing at time of appellate review)
State v. Moore, 846 N.W.2d 83 (appellate deference not given to factfinder’s choice between reasonable inferences)