State v. Zornes
2013 Minn. LEXIS 312
| Minn. | 2013Background
- Zornes was convicted of two counts of first-degree premeditated murder, first-degree arson, and theft of a motor vehicle.
- He appealed on four grounds: public-trial/public-voir-dire sequestration, Fourth Amendment suppression, admission of items found at arrest, and impeachment with prior felonies.
- During Feb. 18–21, 2010, multiple witnesses placed Zornes near the crime scene; Cadotte’s car and a smoke detector were recovered; a digital/phone record trail connected Cadotte and Londo.
- Zornes was arrested March 4, 2010; after Miranda, officers collected evidence and later sought a search warrant; a statement he allegedly made during the search was at issue.
- The district court suppressed the DNA results from the warrantless search, but permitted Zornes’s statement to be admitted; three prior felonies were deemed admissible for impeachment if he testified; Zornes did not testify; he was sentenced to two consecutive life terms plus additional sentences.
- The court ultimately affirmed the conviction on all issues, finding no reversible error in the challenged rulings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Public trial right during voir dire | Zornes—E.M. and Cadotte’s brother exclusion violated public-trial right | Court had discretion to sequester witnesses to prevent tailored testimony | No reversible error; sequestration fell within discretion |
| Statement obtained during unlawful search | Statement should be suppressed as fruit of unlawful search | Statement admissible; harmless error despite unlawful search | Harmless beyond a reasonable doubt; admissible |
| Admissibility of items found at arrest | Knives, hammer, and tools not connected to crime; prejudicial | Items linked to crime; probative value outweighs prejudicial impact | District court did not abuse discretion; items admissible |
| Impeachment with three prior felonies if he testified | Prior convictions highly probative; essential to credibility | Impeachment outweighs potential chilling effect on testimony | Court did not abuse discretion; Jones factors support admission |
Key Cases Cited
- Presley v. Georgia, 559 U.S. 209 (2010) (public trial extends to voir dire; sequestration discretion exists)
- Leeke v. United States, 488 U.S. 272 (1989) (sequestration of witnesses to prevent tailored testimony)
- Garden v. State, 267 N.W.2d 97 (Minn. 1963) (courtroom restrictions for witnesses within voir dire discretion)
- Waller v. Georgia, 467 U.S. 39 (1984) (need overriding interest to close hearings; public-trial concerns)
- Geders v. United States, 425 U.S. 80 (1976) (broad power to sequester witnesses; voir dire context)
- Lubenow, 310 N.W.2d 52 (Minn. 1981) (limitations on admitting physical evidence that could have caused injuries)
- Gayles v. State, 327 N.W.2d 1 (Minn. 1982) (connection between possession of weapon and crime; evidentiary relevance)
- Jones v. State, 271 N.W.2d 534 (Minn. 1978) (five-factor test for admissibility of prior convictions for impeachment)
- Caulfield v. State, 722 N.W.2d 304 (Minn. 2006) (harmless-error analysis for admission of contested evidence)