State v. Satoskar
| Docket Number | A21-0854 |
| Decision Date | 31 May 2022 |
| Parties | State of Minnesota, Respondent, v. Randip E. Satoskar, Appellant. |
| Court | Minnesota Court of Appeals |
This opinion is nonprecedential except as provided by Minn. R Civ. App. P. 136.01, subd. 1(c).
Dakota County District Court File No. 19HA-CR-20-146
Keith Ellison, Attorney General, St. Paul, Minnesota; and Kathryn M. Keena, Dakota County Attorney, Jessica Bierwerth Assistant County Attorney, Hastings, Minnesota (for respondent)
Cathryn Middlebrook, Chief Appellate Public Defender, Anders J. Erickson, Assistant Public Defender, St. Paul, Minnesota (for appellant)
Considered and decided by Gaïtas, Presiding Judge; Bjorkman, Judge; and Frisch, Judge.
Appellant Randip E. Satoskar challenges his conviction for first-degree arson following a jury trial. He argues that the district court violated his right to a speedy trial, that the trial evidence was insufficient to support his conviction, that the district court committed reversible error by failing to formally enter a competency finding after his competency evaluation, that his waiver of trial counsel was invalid, and that the district court plainly erred in its jury instructions. We affirm.
Emergency workers responded to a report of a fire at Satoskar's house in West St. Paul on July 12, 2019. The fire department searched the house for occupants and initially found no one inside. But during a second search, they found Satoskar crawling out from under a bed in the northeast bedroom. Satoskar asked the firefighters what they were doing in his house. He was taken outside where police observed that he was "soaking wet, . . . covered in soot, [with] scratches on him, he was bleeding from several spots . . ., and he was unable to sit still." Officers found Satoskar's behavior to be "very suspicious."
A fire investigation revealed that the fire started in the northeast bedroom where Satoskar was found. Investigators found unburned fire starter and an unburned matchstick near the fire's point of origin. Initially, investigators deemed the cause of the fire to be "undetermined," but they ultimately classified it as "incendiary," meaning it was intentionally started.
Two days after the fire, on July 14, 2019, Satoskar's neighbor called 911 to report a fire alarm and large quantities of smoke billowing from Satoskar's window. While the neighbor spoke to the 911 dispatcher, he observed Satoskar in the backyard. He reported that Satoskar "was not wearing a shirt, was walking around in . . . sort of a stupor, carrying a red container, and making no attempt to either extinguish the fire or get help."
Police officers found Satoskar hiding in the rafters of his detached garage and attempting to ignite the structure with a blowtorch. When Satoskar did not follow orders to come down from the rafters, officers "pointed firearms at him, sprayed pepper spray at him, and shot non-lethal bullets at him" before finally getting him to comply using a stun gun. After arresting Satoskar, officers found two torch devices-one in the rafters and another in his pocket.
During the investigation of the second house fire, officers looked for accelerants in the northeast bedroom, which was again identified as the point of origin. The baseboard contained a "medium petroleum distillate," an accelerant that exists in "thousands" of everyday products. Investigators concluded that the July 14 house fire was also intentionally started. They also determined that it was a different fire than the one that had occurred two days before.
On January 17, 2020, respondent State of Minnesota charged Satoskar with two counts of first-degree arson for "unlawfully by means of fire or explosives, intentionally destroy[ing] or damag[ing] any building that is used as a dwelling" on July 12 and July 14, respectively. See Minn. Stat. § 609.561, subd. 1 (2018). The state later amended the complaint, with the district court's permission, to charge just a single count of arson for both fires.[1] Id. Although Satoskar was initially represented by counsel, he later waived counsel and represented himself, including at trial.[2]
Satoskar demanded a speedy trial on March 25, 2020 and eight times thereafter. Various factors delayed the trial, including the suspension of all jury trials in Minnesota due to the COVID-19 pandemic, a motion by Satoskar's counsel for a rule 20.01 competency evaluation, the prosecutor's development of COVID-19 symptoms, and an additional 60-day pause on jury trials in the state due to COVID-19. While awaiting his trial, Satoskar remained in jail and made multiple requests for release pending trial due to the delay, all of which were denied. The trial eventually commenced on January 4, 2021, but when a juror fell ill, the district court declared a mistrial. A second jury trial began on January 25, 2021. Satoskar moved for a continuance so that he could pursue private investigative services to aid in his defense. The district court denied his motion.
The jury found Satoskar guilty of the charged offense of first-degree arson. Following the jury's verdict, the district court sentenced Satoskar to 48 months in prison and ordered him to pay $151, 162.15 in restitution.
Satoskar appeals.
Satoskar argues that the 285-day delay in bringing him to trial after his speedy-trial demand violated his constitutional right to a speedy trial.
The federal and Minnesota constitutions provide criminal defendants the right to a speedy trial. U.S. Const. amends. VI, XIV; Minn. Const. art. I, § 6. The Minnesota Rules of Criminal Procedure also provide that:
Appellate courts review alleged violations of a defendant's Sixth Amendment right to a speedy trial de novo. State v. Griffin, 760 N.W.2d 336, 339 (Minn.App. 2009). To determine whether a delay rises to the level of a violation of the constitutional speedy-trial right, reviewing courts use the balancing test set forth by the United States Supreme Court in Barker v. Wingo, 407 U.S. 514 (1972). State v. Mikell, 960 N.W.2d 230, 244 (Minn. 2021); State v. Windish, 590 N.W.2d 311, 315 (Minn. 1999). This test requires courts to consider the following factors, known as the Barker factors, in determining whether the right was violated: "(1) the length of the delay; (2) the reason for the delay; (3) whether the defendant asserted his or her right to a speedy trial; and (4) whether the delay prejudiced the defendant." Windish, 590 N.W.2d at 315; Barker, 407 U.S. at 530-33.
A 60-day delay is presumptively prejudicial and requires a weighing of the latter three factors. Windish, 590 N.W.2d at 315-16. None of these factors alone is "either a necessary or sufficient condition to the finding of a deprivation of the right of speedy trial." Barker, 407 U.S. at 533. An evaluation of the Barker factors "is not a check-the-box, prescriptive analysis," and instead involves an assessment of "how the factors interact with each other in a difficult and sensitive balancing process." Mikell, 960 N.W.2d at 245 (quotation omitted). Reviewing courts may also consider "other circumstances as may be relevant." Barker, 407 U.S. at 533.
To determine whether the delay in bringing Satoskar to trial violated his constitutional right to a speedy trial, we now consider each of the Barker factors in turn.
First, as noted, "[t]he length of the delay is a triggering mechanism which determines whether further review is necessary." Windish, 590 N.W.2d at 315 (quotation omitted). Here, Satoskar made his first speedy-trial demand on March 25, 2020 and later reasserted that demand. Satoskar's first jury trial began on January 4, 2021-285 days after his first speedy-trial demand. After that trial ended in a mistrial due to a juror's illness, [3] Satoskar's second jury trial began on January 25, 2021. Because the delay Satoskar experienced exceeded 60 days, which triggered a presumption of prejudice, we must address the other Barker factors. See Windish, 590 N.W.2d at 315.
The second factor is the reason for delay. If there is good cause for the delay, there may be no violation of the speedy-trial right. Griffin, 760 N.W.2d at 340.
Here there were multiple causes for the delay, many of which were related to the COVID-19 pandemic. Between Satoskar's initial speedy-trial demand on March 25, 2020 and July 20, 2020-a total of 118 days-the delays were attributable to COVID-19-related court closures. The district court initially scheduled a trial for May 11, 2020, which fell within the 60-day speedy-trial window under the rules of criminal procedure. See Minn. R. Crim. P. 11.09(b). But by May 11, an order issued by the Chief Justice of the Minnesota Supreme Court barred jury trials in the interest of public health. See Continuing Operations of the Courts of the State of Minnesota Under a Statewide Peacetime Declaration of Emergency, No. ADM20-8001 (Minn. Mar. 20, 2020). Satoskar's trial was rescheduled to June 22, 2020, which still fell within the 60-day window, but jury trials had not yet resumed due to statewide pandemic restrictions. See Order Governing the Continuing Operations of the Minnesota Judicial Branch Under Emergency Executive...
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