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State v. Hall

Supreme Court of Minnesota

July 31, 2019

State of Minnesota, Appellant,
v.
Marie Jessica Hall, Respondent.

          Court of Appeals Office of Appellate Courts

          Keith Ellison, Attorney General, Saint Paul, Minnesota; and Michael O. Freeman, Hennepin County Attorney, Jean Burdorf and Brittany D. Lawonn, Assistant County Attorneys, Minneapolis, Minnesota, for appellant.

          Cathryn Middlebrook, Chief Appellate Public Defender, Sharon Jacks, Assistant Public Defender, Saint Paul, Minnesota, for respondent.

          Travis J. Smith, Murray County Attorney, and Adam E. Petras, Assistant Ramsey County Attorney, for amicus curiae Minnesota County Attorneys Association.

         SYLLABUS

         To prove third-degree murder under Minn. Stat. § 609.195(a) (2018), the State is not required to prove that the defendant lacked an "intent to effect the death of any person."

         Reversed and remanded.

          OPINION

          MCKEIG, JUSTICE.

         This case presents the question of whether the third-degree murder statute requires the State to prove beyond a reasonable doubt that the defendant lacked an "intent to effect the death of any person." The district court found respondent Marie Jessica Hall guilty of several offenses, including third-degree murder. The third-degree murder statute states:

Whoever, without intent to effect the death of any person, causes the death of another by perpetrating an act eminently dangerous to others and evincing a depraved mind, without regard for human life, is guilty of murder in the third degree and may be sentenced to imprisonment for not more than 25 years.

         Minn. Stat. § 609.195(a) (2018) (emphasis added). On appeal, Hall raised three claims, including a claim that there was insufficient evidence to support her conviction because the State failed to prove beyond a reasonable doubt that she lacked an intent to effect the death of any person. More specifically, Hall argued that the district court's finding that her "driving conduct was an apparent suicide attempt" reflected, contrary to the text of the statute, an intent to effect the death of a person, namely herself. Persuaded by Hall's argument, the court of appeals reversed Hall's conviction without considering Hall's alternative argument that her conduct did not evince a depraved mind. Because the third-degree murder statute does not require the State to prove beyond a reasonable doubt that the defendant lacked an intent to effect the death of any person, we reverse and remand for consideration of Hall's alternative argument.

         FACTS

         Hall is a 26-year-old woman with a history of mental illness involving periods of psychosis. On January 28, 2016, Hall crashed the SUV that she was driving into a City of Bloomington maintenance truck, killing the passenger in the truck and severely injuring the other occupant. The State charged Hall with third-degree murder, Minn. Stat. § 609.195(a), criminal vehicular homicide, Minn. Stat. § 609.2112, subd. 1(a)(1) (2018), and criminal vehicular operation, Minn. Stat. § 609.2113, subd. 1(1) (2018). Hall asserted a mental-illness defense and waived her right to jury trial. The district court bifurcated the bench trial into a guilt phase and a mental-illness phase.

         The district court made the following findings of fact. During the week leading up to the crash, Hall was in the midst of a mental illness episode. The morning of the crash, Hall cut all of the electronic cords in her apartment, threw condiments, dish soap, and flour all over the walls and ceiling, and put her furniture into strange positions, among other acts. Fixated on the idea that she must die to get into Heaven, Hall decided to kill herself. She got into her car and drove to a Sam's Club, where she grabbed two bottles of vodka, threw money into the air, then left. Once inside her car, Hall drank about four shots of vodka before driving out of the parking lot.[1] Surveillance video from Sam's Club shows that she left the parking lot at 10:20 a.m.

         Hall was driving at a rate of about 100 miles per hour and was still pressing the accelerator when she crashed into the maintenance truck near the intersection of American Boulevard and Portland Avenue South, in the City of Bloomington. There were "many other" cars on the road at the time. According to Hall, she did not apply her brakes before the crash because she was trying to "end all be all;" she believed that "you must die by the flesh to get to heaven." Hall knew her actions put others at risk, and her conduct was "an apparent suicide attempt."

         Based on its findings of fact, the district court determined that Hall had caused the death of another, by perpetrating an act eminently dangerous to others, which evinces a depraved mind regardless of human life, and, therefore, she was guilty of third-degree murder.[2]

         During the mental-illness phase, the district court considered whether Hall's mental illness prevented her from understanding the nature of her act, or that it was wrong. See Minn. Stat. § 611.026 (2018) ("[A] person shall not be excused from criminal liability except upon proof that at the time of committing the alleged criminal act the person was laboring under such a defect of reason, from one of these causes, as not to know the nature of the act, or that it was wrong."). Although the district court acknowledged that it was a "close call," it ultimately determined that Hall failed to meet her burden to prove the defense of mental illness by a preponderance of the evidence. Hall was sentenced to 100 months in prison, a downward durational departure, for her third-degree murder conviction.

         Hall timely appealed her conviction to the court of appeals, raising three arguments. First, Hall argued there was insufficient evidence to support her conviction because the State failed to prove beyond a reasonable doubt that she lacked an intent to effect the death of any person, contrary to Minn. Stat. ยง 609.195(a). Second, she argued that the evidence did not establish that she acted with a depraved mind. Third, Hall argued that the district ...


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