State v. Harris

• Decision Date: 24 May 2017
• Docket Number: A15-0711
• Citation: 895 N.W.2d 592
• Parties: STATE of Minnesota, Appellant, v. Carlos Maurice HARRIS, Respondent.
• Court: Minnesota Supreme Court

895 N.W.2d 592

STATE of Minnesota, Appellant,

v.Carlos Maurice HARRIS, Respondent.

A15-0711

Supreme Court of Minnesota.

Filed: May 24, 2017

Michael O. Freeman, Hennepin County Attorney, Linda K. Jenney, Assistant County Attorney, Minneapolis, Minnesota, for appellant.

Cathryn Middlebrook, Chief Appellate Public Defender, Rochelle R. Winn, Assistant Public Defender, Saint Paul, Minnesota, for respondent.

Lori Swanson, Attorney General, Matthew Frank, Assistant Attorney General, Saint Paul, Minnesota, for amicus curiae Minnesota Attorney General.

Daniel J. Koewler, Ramsay Law Firm, PLLC, Roseville, Minnesota, for amicus curiae Minnesota Association of Criminal Defense Lawyers.

Robert Small, Executive Director, Minnesota County Attorneys Association, Saint Paul, Minnesota; and Nicholas A. Hydukovich, Assistant Washington County Attorney, Stillwater, Minnesota, for amicus curiae Minnesota County Attorneys Association.

Robin M. Wolpert, Sapientia Law Group, PLLC, Minneapolis, Minnesota; and Charles F. Webber, Faegre Baker Daniels LLP, Minneapolis, Minnesota, for amicus curiae Minnesota State Bar Association, Criminal Law Section.

OPINION

ANDERSON, Justice.

A jury found respondent Carlos Harris guilty of possession of a firearm by an ineligible person. The court of appeals reversed, concluding that the evidence presented at trial was insufficient to support the jury's verdict. Appellant State of Minnesota petitioned for review, asserting that the court of appeals erred in its application of the law and asking us to abandon the separate standard of review for convictions based on circumstantial evidence. We conclude that the court of appeals correctly applied the law and we decline the invitation to overrule our precedent. We therefore affirm the court of appeals.

FACTS

On March 4, 2014, a police officer working with a United States Marshals task force was looking for J.A. based on an arrest warrant. The officer began surveillance in an area where information indicated that J.A. could be found. The officer observed J.A. get into the passenger seat of a Cadillac car and watched the car drive away. Police later learned that Harris was driving the car; J.A. was in the front passenger seat; and another person, K.E., was seated behind Harris. They also learned that the car was owned by Harris's brother.

The officer followed the car in an unmarked police vehicle. He did not immediately attempt to stop the car because he was concerned about possible danger to bystanders and was waiting for additional police support.

Eventually, after additional law enforcement arrived, the officer activated his lights and siren in an attempt to stop the car. The emergency lights were more noticeable than normal and were described as lighting up the officer's vehicle "like a Christmas tree." The car continued traveling between 30 and 35 miles an hour for approximately three blocks. The officer saw movement inside the car. As the car approached the freeway, the officer feared the occupants might attempt to flee, so he pulled his vehicle alongside the car, causing it to stop at the curb.

Several police officers then approached the car and ordered the occupants to show their hands. Although Harris initially complied with this command, at some point he lowered his hands below the window. However, when commanded to raise his hands again, he did so. Harris was removed from the car first.

J.A. was less cooperative. When police told J.A. to show his hands, J.A. refused to do so. He also made furtive movements in his lap and near the glove compartment. Eventually, J.A. complied with police commands to get out of the car; but after getting out of the car, J.A. reached his hand into the car again.

The backseat passenger, K.E., was the last person removed from the car. Police then secured Harris, J.A., and K.E. in three separate squad cars and inspected the Cadillac to ensure that nobody else was hiding in it. When police looked up, to the right of, and slightly behind the driver's seat, they saw that the headlining of the car had been altered.¹ The car had a sunroof in the middle of the roof. A panel slides back into the headlining to expose the glass of the sunroof and allow light into the car. When police searched the car, the panel was slid back. However, the void into which the panel usually retracts had been expanded because the headlining had been pulled down a few inches. The officer noticed the butt end of a firearm partially sticking out of this void.

The firearm was a .45-caliber Springfield model 1911 with a "huge" magazine attached to it. There were "quite a few" rounds in the magazine and one in the chamber. The firearm was cocked and ready to fire.

The State charged Harris with possession of a firearm by an ineligible person under Minn. Stat. § 624.713, subd. 1(2) (2016). At trial, the parties stipulated that Harris was ineligible to possess a firearm, so the only issue the jury considered was whether Harris possessed the firearm. The State introduced forensic evidence at trial showing that the firearm contained a mixture of male and female DNA from five or more people. Approximately 75.7% of the general population could be excluded as contributors to this DNA mixture, but Harris, J.A., and K.E. could not. The State presented circumstantial evidence that Harris possessed the firearm, and the jury returned a guilty verdict. The court of appeals reversed the conviction, concluding that the circumstantial evidence was insufficient to convict Harris of the offense. State v. Harris , No. A15-0711, 2016 WL 1396689 (Minn. App. Apr. 11, 2016). We granted the State's petition for review.

ANALYSIS

I.

As an initial matter, we turn to the standard of review. The State argues that the court of appeals erred by engaging in "fine-grained factual parsing" of the evidence and that this error demonstrates that our standard of review for convictions based on circumstantial evidence is unnecessarily complicated, confusing, misleading, and difficult to apply. The State urges us to abandon this standard of review and adopt in its place a unified standard of review that applies to all evidence, circumstantial or otherwise.

For approximately a century, we have applied a separate standard of review to challenges to the sufficiency of circumstantial evidence.² State v. Johnson , 173 Minn. 543, 217 N.W. 683, 684 (1928). Under that standard, we identify the circumstances proved and independently consider the reasonable inferences that can be drawn from those circumstances, when viewed as a whole. State v. Andersen , 784 N.W.2d 320, 329 (Minn. 2010) ; see State v. Robertson , 884 N.W.2d 864, 871-72 (Minn. 2016) (considering whether "[w]hen viewed as a whole, the circumstances proved support[ed] a rational inference that Robertson was the shooter"); State v. Silvernail , 831 N.W.2d 594, 599 (Minn. 2013) (explaining that "[w]e review the circumstantial evidence not as isolated facts, but as a whole"). "To sustain a conviction based on circumstantial evidence, the reasonable inferences that can be drawn from the circumstances proved as a whole must be consistent with the hypothesis that the accused is guilty and inconsistent with any rational hypothesis except that of guilt." State v. Fox , 868 N.W.2d 206, 223 (Minn. 2015).

This circumstantial-evidence standard dates back to at least 1928, and possibly earlier. Johnson , 217 N.W. at 684 ("[A]ll the circumstances proved must be consistent with the hypothesis that the accused is guilty and inconsistent with any rational hypothesis except that of his guilt." (citing State v. Johnson , 37 Minn. 493, 35 N.W. 373, 376 (1887) ). It has remained our law ever since. See State v. Cox , 884 N.W.2d 400, 411 (Minn. 2016) ("To sustain a conviction based on circumstantial evidence, the reasonable inferences that can be drawn from the circumstances proved must be consistent with the hypothesis that the accused is guilty and inconsistent with any rational hypothesis other than guilt."); State v. Taylor , 650 N.W.2d 190, 206 (Minn. 2002) ("Circumstantial evidence must form a complete chain that, in view of the evidence as a whole, leads so directly to the guilt of the defendant as to exclude beyond a reasonable doubt any reasonable inference other than guilt."); State v. Scharmer , 501 N.W.2d 620, 622 (Minn. 1993) (reversing convictions because "[t]he evidence did not form a complete chain leading so directly to appellant's guilt as to exclude beyond a reasonable doubt any rational hypothesis except that of his guilt"); State v. Webb , 440 N.W.2d 426, 431 (Minn. 1989) (reversing a conviction because "[t]he circumstantial evidence was not inconsistent with rational hypotheses other than guilt").

We are "extremely reluctant" to overrule our precedent absent a compelling reason to do so. State v. Lee , 706 N.W.2d 491, 494 (Minn. 2005).³ The State offers several reasons for overruling Johnson , but none are compelling.

First, the State argues that many other jurisdictions have abandoned a separate circumstantial-evidence standard of review, opting instead for a unified standard of review that applies to all convictions. See Easlick v. State , 90 P.3d 556, 557 & n.1 (Okla. Crim. App. 2004) (listing states that apply a unified standard of review when examining the sufficiency of both direct and circumstantial evidence). Although previously we have considered the practice of other states in deciding whether to overrule our precedent, see Cargill, Inc. v. Ace Am. Ins. Co ., 784 N.W.2d 341, 352-53 (Minn. 2010) (noting that our precedent was "the minority view" among other courts), we never have held that the extent to which other jurisdictions have adopted a different approach is, by itself, a compelling reason to overrule our precedent. We are similarly unpersuaded by the State's argument here.

Next, the State argues that the circumstantial-evidence standard of review rests on outdated views of the differences between direct and circumstantial evidence. We have...