Eason v. State, A19-1664
Decision Date | 28 October 2020 |
Docket Number | A19-1664 |
Citation | 950 N.W.2d 258 |
Parties | Jamil Joshua EASON, Appellant, v. STATE of Minnesota, Respondent. |
Court | Minnesota Supreme Court |
A Hennepin County jury found appellant Jamil Joshua Eason guilty of first-degree intentional felony murder in connection with the November 2012 death of Jay Arthur Rosio. Eason filed a direct appeal, but voluntarily dismissed his appeal before the State filed its responsive brief. In 2016, Eason filed a pro se petition for postconviction relief and requested appointment of counsel. After the district court denied the request for counsel and the petition, Eason appealed. We concluded that the district court erred in not granting the request to appoint counsel, and remanded the case for appointment of counsel and further postconviction proceedings. State v. Eason , 906 N.W.2d 840, 843 (Minn. 2018).
Following remand, appointment of counsel, and a hearing, the case now comes to us on Eason's appeal of the district court's denial of his petition for postconviction relief. Because the district court did not abuse its discretion, we affirm.
On November 2, 2012, appellant Jamil Joshua Eason stabbed and strangled Jay Arthur Rosio during a burglary and lit Rosio's home on fire. Minneapolis firefighters responding to the fire found Rosio dead on the basement floor and notified the police after discovering stab wounds. A later investigation discovered that the fire, which came from several sources of accelerant, had been intentionally set.
An autopsy determined that Rosio had died of complex homicidal violence. He suffered 16 blunt force injuries and at least 4 chop wounds to the head, several wounds to the face, 2 or 3 stab wounds to the trunk, at least 13 blunt force injuries to the extremities, and cuts on his hands. Rosio's body showed signs of strangulation as well. In addition, Rosio's heightened carbon monoxide level suggested that he was breathing for a time after the fire was set. Eason was subsequently arrested, charged with second-degree intentional murder, and indicted on first-degree intentional felony murder.
While in jail awaiting trial, Eason confessed his crime to another inmate, R.L. Eason told R.L. that he broke into Rosio's home to steal electronics. Eason told R.L. that, once inside, he heard a noise and went downstairs to investigate. There he encountered Rosio, who was startled and asked Eason what he was doing. Eason told Rosio that he was there to rent a place. In describing what happened next, Eason told R.L. that when Rosio turned away, he "choked the old guy out." As Eason started looking for items to steal in the basement, he tripped over Rosio. Rosio awoke, told Eason to leave, and "went for a knife."1 Eason told R.L. that he "snatched the knife" and "went all ham on him," which R.L. interpreted to mean that Eason had "gone crazy on [Rosio]." Eason further confided that in the struggle Eason had cut Rosio on top of the head and stabbed him in the chest. Eason told R.L. that after Rosio stopped moving, Eason gathered items to steal, cleaned off the knife and himself, set the home on fire, and left. After Eason confessed, R.L. contacted police.
Because two of Eason's claims before us concern unsuccessful plea negotiations, we set forth the history of the negotiations in detail. The week before Eason's trial, the prosecutor offered a plea agreement with a sentencing range of between 420 to 480 months based upon a guilty plea to second-degree intentional murder and agreement to two aggravating sentencing factors. Eason declined the offer on the record. The district court then asked Eason whether he understood the plea offer, and if he had had time to speak with his counsel about it. Eason said that he did. The district court further asked Eason "[a]nd do you understand that if you don't accept the offer, the offer is rejected, it's not like just sitting out on the table for you to accept some other time later?" Eason responded, "[y]es sir."
On the second day of jury selection, Eason made a counteroffer of 360–480 months, which the prosecutor discussed with her supervisors and declined. Eason's attorney responded by asking whether the original offer was still available, and the prosecutor informed him that it was not.
Later that day, the prosecutor made a "last and final offer" on the record to allow Eason to plead guilty to second-degree intentional murder for an aggravated sentence of 480 months. The last and final offer also required Eason to waive his right to a hearing under Blakely v. Washington , 542 U.S. 296, 124 S.Ct. 2531, 159 L.Ed.2d 403 (2004), and admit to two aggravating factors. Eason was present when the offer was made. The judge responded, The court recessed, and Eason conferred with his attorneys.
During the recess, Eason's attorneys did not discuss the last plea offer. Rather, after receiving Eason's consent, Eason's attorneys approached the prosecutor and asked if she would allow Eason to plead guilty to the previously offered 420–480 month sentence. The prosecutor declined Eason's request. Eason's attorney made a record of this conversation and the State's rejection, expressing his frustration and stating that "there is absolutely no reason that [the State] should not leave the original offer of 420 to 480 on the table." Jury selection then continued. No further plea negotiations ensued.
Eason's three-day trial included testimony from firefighters, police officers, and experts from the Bureau of Criminal Apprehension who described the crime scene, Rosio's injuries, and the murder investigation. The jury also heard testimony from two witnesses that, on the night that Rosio was murdered, Eason had gone to a barbershop and sold a laptop and cell phone that he had stolen from Rosio. R.L., the informant, also testified. Eason did not testify and called no witnesses. At the close of the evidence, Eason's attorneys asked the district court to submit jury instructions on the lesser-included offenses of first-degree heat of passion manslaughter and second-degree unintentional felony murder. The district court denied the request. The jury subsequently found Eason guilty of first-degree intentional felony murder even though it had the opportunity to find him guilty of the lesser-included offense of second-degree intentional murder. The district court sentenced Eason to life in prison with the possibility of supervised release after thirty years.
Eason timely filed a notice of appeal, but then voluntarily dismissed this direct appeal. See State v. Eason , 906 N.W.2d 840, 841 (Minn. 2018) ( ). In 2016, Eason filed a pro se petition for postconviction relief and requested appointment of counsel. Id. The district court denied Eason's postconviction petition without holding an evidentiary hearing or appointing counsel. Id.
Upon Eason's appeal from this decision, we concluded that Eason's right to counsel had not been fully vindicated. We therefore remanded his case to the district court for appointment of counsel to represent Eason in a first review by postconviction proceeding. Id. at 843.
With assistance of counsel, Eason filed a petition for postconviction relief contending that: (1) the judge who presided over his trial committed reversible error by denying his request for lesser-included jury instructions; (2) the prosecutor had abused her prosecutorial discretion in plea negotiations; and (3) he received ineffective assistance of trial counsel during the plea negotiations. The district court denied Eason's claims related to the jury instructions and prosecutorial discretion, but granted an evidentiary hearing to determine whether Eason received ineffective assistance of counsel.
At the postconviction evidentiary hearing, the district court heard testimony from Eason's two trial lawyers and the prosecutor. Eason's defense attorneys each stated that they did not discuss the State's last and final offer with Eason. Eason also testified, stating that he would have been willing to accept the State's last plea offer and to provide a sufficient factual basis to admit guilt.
After assessing the credibility of the witnesses, the district court made findings of fact and reached several conclusions, including that Eason State's offers. "Throughout the process of plea negotiations, Eason was influenced by others in custody who were, apparently, telling him to not plead." Trial counsel "reasonably believed [Eason] would not accept a plea of 480 months, if asked again." The district court noted that Eason's confession at the last evidentiary hearing "seemed driven more by a sense of buyer's remorse than by a true representation of what he would have done at the time." The district court was "not satisfied that Eason would have pleaded or would have been able to lay an adequate factual basis at the time of trial." Finally, the district court concluded that it was "unlikely the State would have accepted [Eason's] plea."
Accordingly, the district court concluded that Eason's claim of ineffective assistance of trial counsel failed under each prong of the test announced in Strickland v. Washington , 466 U.S. 668, 104 S.Ct. 2052, 80 L.Ed.2d 674 (1984). Eason now appeals.
We review the district court's denial of Eason's requested postconviction relief for an abuse of discretion. Davis v. State , 784 N.W.2d 387, 390 (Minn. 2010). A district court "abuses its discretion when its decision is based on an erroneous view of the law or is against logic and the facts in the record."
Riley v. State , 819 N.W.2d 162, 167 (Minn. 2012). In making this determination, we review a district court's factual determinations for clear error, Scherf v. State , 788 N.W.2d 504, 507 (Minn. 2010), and review the district court's legal conclusions de novo, Leake v. State , 737 N.W.2d 531, 535 (Minn. 2007...
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