accomplice liability instruction in Minnesota

2017In Milton , the supreme court held that an accomplice-liability instruction is erroneous if it “allow[s] the jury to find [the defendant] guilty as an accomplice without first finding that [the defendant] knowingly and intentionally assisted in the commission of a crime.” 821 N.W.2d at 805-06 .

2017It went on to prescribe that an accomplice-liability instruction must explain to the jury that “in order to find a defendant guilty as an accomplice, the jury must find beyond a reasonable doubt that the defendant knew his alleged accomplice was going to commit a crime and the defendant intended his presence or actions to further the commission of that crime.” Id. at 808 .

2024At trial, Segura requested that the district court add language drawn from Rosemond v. United States, 572 U.S. 65 (2014), to the accomplice liability instruction recommended by the jury instruction guides.

2024At trial, Segura requested that the district court add language drawn from Rosemond v. United States, 572 U.S. 65 (2014), to the accomplice liability instruction recommended by the jury instruction guides.

2016Specifically, he argues that the district court erred by not giving an accomplice-liability instruction and that the absence of such an instruction prevented the jury from fully considering his defense that “he was at the scene but did not intend his actions to aid [J.W.]” A district court must instruct the jury in a way that “fairly and adequately explain[s] the law of the case” and does not “materially misstate[] the applicable law.” State v. Koppi, 798 N.W.2d 358, 362 (Minn. 2011).

2016Such an error is grounds for reversal “only if it seriously affects the fairness, integrity, or public reputation of judicial proceedings.” State v. Taylor, 869 N.W.2d 1, 15 (Minn. 2015) (quotations omitted).

2016An appellate court reviews jury instructions “as a whole to determine whether [they] accurately state the law in a manner that can be understood by the jury.” State v. Kelley, 855 N.W.2d 269, 274 (Minn. 2014).

2016Specifically, “an accomplice liability instruction must explain that the intentionally aiding element requires that the jury find beyond a reasonable doubt that the defendant knew his alleged accomplice was going to commit a crime and the defendant intended his presence or actions to further the commission of that crime.” Kelley, 855 N.W.2d at 274 .

2015Id. at 812, 814 .

2015State v. Larson, 787 N.W.2d 592, 603 (Minn. 2010). 11 At its core, any definition of “accomplice” must include some conjunctive act or mutual intent involving two or more people.

2014Had Kelley contemporaneously objected to the accomplice-liability instruction at trial and referred the district court to State v. Mahkuk, 736 N.W.2d 675, 682 (Minn. 2007)—the case relied upon in Milton—it is possible the district court would have concluded that the model accomplice-liability jury instruction was deficient and would have corrected the instruction.

2014Had Kelley contemporaneously objected to the accomplice-liability instruction at trial and referred the district court to State v. Mahkuk, 736 N.W.2d 675, 682 (Minn.2007)—the case relied upon in Milton — it is possible the district court would have concluded that the model accomplice-liability jury instruction was deficient and would have corrected the instruction.

2014State v. Kelley, 832 N.W.2d 447, 451-52 (Minn. App. 2013).

2014State v. Kelley, 832 N.W.2d 447, 451-52 (Minn.App.2013).

2013In State v. Brown, 815 N.W.2d 609, 620-21 (Minn.2012), however, we concluded that an accomplice-liability instruction that featured language about “presence” that was similar to the instruction challenged by Bahtuoh, and materially identical to the language criticized in Mahkuk , was not erroneous.

2010See Evans, 756 N.W.2d at 877 ; State v. Swanson, 707 N.W.2d 645, 658 (Minn.2006).

2010See Evans, 756 N.W.2d at 877 ; State v. Swanson, 707 N.W.2d 645, 658 (Minn.2006).