EvidenceProf Blog

Editor: Colin Miller
Univ. of South Carolina School of Law

Thursday, August 11, 2011

Guilt By Association?: Court Of Appeals Of Minnesota Finds Possibly Erroneous Admission Of Guilty Plea To Be Harmless

Let's say that a defendant is charged with murder and assault based upon allegedly having another man punch a woman he had impregnated. And let's say that the other man pleads guilty to crimes connected with the punching during a guilty plea hearing, implicating the defendant in the process.  If the court errs by admitting the transcript of the other man's guilty plea hearing at the defendant's trial, can the error be harmless? According to the recent opinion of the Supreme Court of Minnesota in State v. Gatson, 2011 WL 3300351 (Minn. 2001), the answer is "yes."

In Gatson
On April 21, 2007, Shyloe Linde was at her friend's apartment...At that time, Linde was six months pregnant with {Dameon] Gatson's baby. Shortly before 11 a.m. that morning, a young, African–American man wearing a light blue sweatshirt knocked on the door of the apartment asking to speak with Linde. Linde did not recognize the man and refused to speak with him, but the man persisted and Linde eventually agreed to talk to him. After she stepped into the hallway, the man punched Linde in the stomach two times and ran away. Linde immediately began having contractions.
Linde was taken to Hennepin County Medical Center where doctors performed an emergency caesarean section to deliver the baby. The baby, who was named Destiny Gatson, weighed just under two pounds, was placed on life support, and had numerous medical procedures over the next nine days in an effort to save her life. During those nine days, Destiny's condition deteriorated and her doctors ultimately recommended removing her life support. Destiny's life support was removed on May 1, 2007, and she died soon after.

The government believed that Paul Petersen punched Linde and charged him in connection with the assault. At a guilty plea hearing, Peterson pled guilty to the crimes against him. Gatson was later charged with first-degree premeditated murder and second-degree murder for aiding Petersen in the killing of Destiny and first-degree assault for aiding Petersen in the assault on Linde. Petersen did not testify at Gatson's trial, but

a portion of the transcript of Petersen's guilty plea hearing was read at Gatson's trial, through which the jury learned that Petersen admitted being friends with Gatson and that Peterson punched Linde with the intent to kill Linde's unborn child. The transcript of Petersen's guilty plea hearing was read into the record after the trial court determined that Gatson had procured a man named Rashad Arthur Raleigh to threaten Petersen from testifying against Gatson, and that Gatson had therefore forfeited his right to confrontation. In making its determination, the trial court considered Petersen's testimony that, as a result of Gatson's efforts, Petersen had almost been stabbed three times while incarcerated at the Minnesota Correctional Facility in St. Cloud (MCF–St.Cloud), that Raleigh had threatened Petersen while they were both incarcerated at MCF–St. Cloud, and that people had been shooting outside of and at his mother's house.

The trial court allowed for the admission of the transcript by concluding that Gatson engaged in forfeiture by wrongdoing. After he was convicted, Gatson appealed, claiming, inter alia, that there was insufficient evidence to establish that he engaged in forfeiture by wrongdoing (and that Petersen was "unavailable") and that the transcript would be inadmissible as a statement against interest. The Supreme Court of Minnesota, however, found that even if these arguments were correct, the error was harmless:

Here, in addition to Petersen's statements, the State presented evidence that Gatson fabricated an alibi of his whereabouts before and during the time of the assault on Linde; that Gatson initially told police that he did not know who Petersen was; that Gatson called Linde shortly before the assault and learned she was at a friend's apartment; that Gatson drove Petersen to and from the friend's apartment the day of the assault; that Gatson sent Petersen up to the friend's apartment to see Linde at the time of the assault; that shortly after the time the assault on Linde occurred, Petersen ran toward a car yelling, "I did it; let's go; let's go"; and that Gatson drove this car away at a high rate of speed. Based on the overwhelming amount of evidence supporting Gatson's guilt, we conclude that the jury's verdict was surely unattributable to the trial court's error, if any, in admitting Petersen's guilty plea and therefore conclude that any error in admitting Petersen's testimony was harmless beyond a reasonable doubt.



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