State v. Chambers
| Decision Date | 04 March 1999 |
| Docket Number | No. C3-97-2298,C3-97-2298 |
| Citation | 589 N.W.2d 466 |
| Parties | STATE of Minnesota, Respondent, v. Timothy Patrick CHAMBERS, Appellant. |
| Court | Minnesota Supreme Court |
Syllabus by the Court
1. Where a defendant is granted leave to renew his motion for change of venue after voir dire, immediately before trial, but declines to do so, he waives any right he may have had to a change of venue.
2. Consequences of a guilty verdict, such as sentencing, are not an appropriate topic for voir dire examination.
3. Under the specific facts of this case, the trial court did not abuse its discretion in requiring the defendant, a young, healthy male with a history of fleeing police who was facing very serious charges, to wear leg restraints during court appearances.
4. The trial court did not abuse its discretion in precluding irrelevant evidence of police policies.
5. Where evidence of prior bad acts and similar crimes is relevant and material to the case, is necessary to support the state's burden of proof, and is not unfairly prejudicial, the trial court did not abuse its discretion in admitting the evidence.
6. The evidence was sufficient to support conviction for first-degree murder of a peace officer under Minn.Stat. § 609.185(4) (1998).
7. The trial court did not abuse its discretion in refusing to instruct the jury on a lesser-included offense where the jury could not rationally have acquitted the defendant of the greater crime, nor rationally convicted him of the lesser crime.
8. The trial court does not possess the discretion to disregard the mandatory life sentence imposed by Minn.Stat. § 609.184, subd. 2(1) (1996) () for a conviction of first-degree murder of a peace officer under Minn.Stat. § 609.185(4).
9. The legislatively mandated sentence of life imprisonment without possibility of release for a conviction of first-degree murder of a peace officer under Minn.Stat. § 609.185(4), is neither cruel nor unusual in violation of U.S. Const. amend. VIII or Minn. Const. art. 1, § 5.
Michael C. Davis, St. Paul, for appellant.
Michael Hatch, State Attorney General, Thomas R. Ragatz, Assistant Attorney General, St. Paul, Jeffrey Thompson, Rice County Attorney, Faribault, for respondent.
Heard, considered, and decided by the court en banc.
This case involves a first-degree murder conviction resulting from a motor vehicle collision in which a Rice County Sheriff's Deputy was killed. The appellant, Timothy Patrick Chambers, asserts that seven different trial court rulings were erroneous and prejudicial, challenges the mandatory sentence of life imprisonment without parole, and asserts that the evidence was insufficient to support the first-degree murder conviction. We affirm the conviction and sentence.
On May 3, 1996, 17-year-old Chambers walked to the Priordale Mall to fill out a job application. As he was leaving the mall at about 12:30 p.m., Chambers saw a red 1991 Lincoln Town Car in the parking lot with the keys inside. Chambers took the Lincoln, which the owner reported stolen shortly after 12:30 p.m.
Soon thereafter, Deputy Donald Buchan of the Scott County Sheriff's Department saw and stopped Chambers, who was driving the stolen Lincoln. However, as Deputy Buchan started to get out of his vehicle, Chambers ran the Lincoln into Deputy Buchan's squad car and drove away. Deputy Buchan began pursuing Chambers and for a brief period the two vehicles "bounc[ed] off of each other." Chambers was then able to pull ahead of the squad car and Deputy Buchan continued his pursuit.
Despite the fact that several different police departments assisted in the pursuit, Chambers continued to flee, running numerous red traffic lights and hitting a truck that had been stopped at an intersection. Chambers then proceeded south on I-35, repeatedly swerving into the median and between vehicles. Throughout much of the 30-mile pursuit, Chambers was traveling at speeds of 90 to 110 miles per hour.
Hearing about the pursuit on his police radio, Deputy John Liebenstein of the Rice County Sheriff's Department decided to set up a roadblock at the top of the Rice County Road 1 exit ramp, only 2 miles from his home. Deputy Liebenstein informed the dispatcher of his intent and placed his unmarked squad car at the top of the exit ramp, leaving a space of over 12 feet for other vehicles to go around the squad car.
Near the border of Rice and Dakota Counties, two semi-truck drivers attempted to slow Chambers, blocking both lanes of traffic while traveling under the posted speed limit. Chambers drove into the median and around the trucks. Upon getting in front of the trucks, Chambers quickly veered to the right and proceeded up the Rice County Road 1 exit ramp, where Deputy Liebenstein had just finished setting up the roadblock.
Witnesses watched the Lincoln accelerate up the ramp and saw Chambers looking straight ahead. At the top of the ramp, the Lincoln collided with Deputy Liebenstein's squad car. Despite the 12-foot space available for Chambers to steer around the squad car, the Lincoln hit the passenger's side of the squad car directly between the front and rear wheels. At the time of impact, Deputy Liebenstein was either seated in the squad car or standing outside of the squad car leaning into it. He was killed instantly and his body was found approximately 70 feet from the point of the impact.
The investigation revealed no attempts by Chambers to slow down, stop, or steer to avoid the collision. After the collision, the wheels of the Lincoln were locked into a straightforward position, and there was no evidence that the brake lights were on at the time of the crash. The Lincoln, traveling between 93 and 98 miles per hour at the time of impact, left no skid marks.
Chambers was charged with first-degree murder of a peace officer, Minn.Stat. § 609.185(4) (1998), second-degree felony murder, Minn.Stat. § 609.19, subd. 2(1) (1998), fleeing a police officer resulting in death, Minn.Stat. § 609.487, subd. 4(a) (1998), and theft of a motor vehicle, Minn.Stat. 609.52, subd. 2(17) (1998). Pursuant to Minn.Stat. § 260.115 (1998), Chambers was automatically certified to stand trial as an adult.
At trial, the state introduced testimony of an individual who had been incarcerated with Chambers in the Steele County jail following the collision. This individual testified that Chambers said "he would go through anything to get away on that day." He further testified that:
[Chambers said he had seen] a car blocking the ramp as he got--[sic] he made a decision that he wasn't going to be stopped; he was going to go through that and continue, and he said "if the cop wanted to be a hero, he would die a hero." * * * * [H]e said that before the accident he made eye contact with the person in the car and the person reacted like this. [Witness indicates by putting his arms up in front of his face.] * * * * He thought that was quite funny. He was laughing about it as he told me.
The witness described Chambers as being "flip" and "bragging about" the death of the deputy.
Prior to trial, the trial court heard several motions, some of which resulted in rulings that Chambers now asserts were erroneous. Chambers moved to change venue due to substantial pre-trial publicity from newspapers, radio, television and electronic media. Chambers' concern was based on the overall news coverage, with special reference to seven stories and one editorial that appeared in the Northfield News and one article that appeared in the Faribault Daily News. All of these articles were published in 1996. There was also television coverage by the major metropolitan television stations at or about the time of the incident. Most of the reports were factual in nature, although some were not completely accurate. The reports included incorrect statements that Chambers was a high school dropout with over 20 prior arrests and a statement that Deputy Liebenstein was seated inside his squad car at the time of the collision, a fact that was greatly disputed at trial. The trial court denied Chambers' change of venue motion but granted the defense leave to renew its motion following voir dire if the defense was not satisfied with the outcome of jury selection.
The jury selection commenced approximately 1 year after this incident. There were extensive written questions submitted to each juror as well as regular voir dire. The trial court called 115 jurors and excused 54 of them for cause. During voir dire, jurors were questioned extensively regarding their exposure to information about the case. Only one juror to whom the defense objected was seated as a juror and the defense did not renew its venue motion. Although Chambers fails to allege any actual prejudice, he now asserts that a presumption of prejudice exists and that the trial court abused its discretion in refusing to grant a change of venue.
At a two-day motion hearing, the trial court heard several additional motions. The defense made a motion in limine to be permitted to examine potential jurors regarding the mandatory sentence of life imprisonment without possibility of release for a first-degree murder conviction. The trial court denied this motion, reasoning that sentencing was the province of the court rather than the jury. Chambers claims that this denial impeded his right to an impartial jury and urges this court to adopt a new rule permitting examination of jurors regarding sentencing in first-degree murder cases.
The defense also objected to the trial court requiring Chambers to wear leg restraints when he appeared in court. The restraints were worn under his trousers and may have been undetected by the jury. The trial court denied the defense's motion to remove the restraints, citing concern regarding flight based on Chambers' past history of attempts to flee police. Chambers asserts that requiring him to appear before the jury in...
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