State v. Williams

38 Citing cases

  1. State v. Schoenrock

    899 N.W.2d 462 (Minn. 2017)   Cited 9 times
    Concluding that omission of the phrase "with intent to defraud" from jury instruction on the elements of theft by false representation was harmless beyond a reasonable doubt

    On appeal, Schoenrock argued that the district court committed reversible error by refusing to instruct the jury that intent to defraud is a distinct element of theft by false representation. Schoenrock relied heavily on State v. Williams , 324 N.W.2d 154 (Minn. 1982), a case involving payment by a check from an account with insufficient funds. The court of appeals affirmed Schoenrock's convictions, concluding that Williams was distinguishable.

  2. State v. Cox

    798 N.W.2d 517 (Minn. 2011)   Cited 76 times
    Holding that the two classes of defendants were not similarly situated because the statutes criminalizing theft by check and dishonored checks require different mens reas

    Id., subds. 3(2)-3(3); see also State v. Williams, 324 N.W.2d 154, 159-6O (Minn. 1982) (discussing permissive nature of this inference). The theft-by-check statute, on the other hand, requires that the defendant issue a check knowing that she was not entitled to issue it.

  3. State v. Roden

    384 N.W.2d 456 (Minn. 1986)   Cited 41 times
    Holding that lesser offense of issuance of a worthless check is necessarily included within the more serious offense of theft by check

    The lesser offense of issuance of a worthless check is proved by evidence that the defendant issued a worthless or bad check, intending at the time of issuance that the check not be paid. State v. Williams, 324 N.W.2d 154, 159-60 (Minn. 1982); Minn.Stat. § 609.535, subd. 2; 10 Minnesota Practice, Minnesota District Judge's Association CRIMJIG 16.30-.31 (1985). The greater offense of theft by check involves a defendant issuing a check knowing he is not entitled to do so ( i.e., knowingly issuing a bad check) as part of a scheme whereby he intentionally defrauds another person into transferring property to him.

  4. State v. Manzanares

    A12-2069 (Minn. Ct. App. Dec. 23, 2013)

    Strader v. Haley, 216 Minn. 315, 327, 12 N.W.2d 608, 614 (1943). Appellant argues, relying on State v. Williams, 324 N.W.2d 154, 159 (Minn. 1982), that the state failed to show that she intended to deprive her employer of property by deceit, which was required to convict her of aggravated forgery. In Williams, a case involving charges of theft by false representation, the Minnesota Supreme Court held that the district court erred by failing to instruct the jury on the required element of specific intent to defraud, defined as the intention to defraud by permanently depriving another of his property.

  5. Amcon Block Precast, v. Suess

    794 N.W.2d 386 (Minn. Ct. App. 2011)   Cited 5 times
    Noting that one element of Minn. Stat. § 514.02, subd. 1(b), is "fail[ure] to provide the payor with a lien waiver or payment bond"

    Amcon contends that this interpretation conflicts with the common-law rule that, "a corporate officer is criminally liable for his own acts, even if done in his official capacity, and he is liable either directly as a principal or as an aider and abettor." State v. Williams, 324 N.W.2d 154, 157 (Minn. 1982). A prior version of section 514.02, subdivision 1, imposed criminal liability on any "person" who committed a theft of proceeds. Minn. Stat. § 514.02, subd. 1 (1998).

  6. State v. Smith

    448 N.W.2d 550 (Minn. Ct. App. 1989)   Cited 48 times
    Holding that reckless misrepresentation is "material" if there is not probable cause to issue search warrant when misrepresentation is set aside

    We agree a jury instruction on burden of proof concerns a fundamental principle of law, and may be raised on appeal regardless of whether an objection was made at trial. See State v. Williams, 324 N.W.2d 154, 160 (Minn. 1982) (where intent is element of an offense, trial court may not prejudge the issue by a jury instruction). However, we do not agree that the challenged jury instruction shifted the burden of proof.

  7. Greene v. Environmental Development Corp.

    415 N.W.2d 374 (Minn. Ct. App. 1987)   Cited 4 times

    Intent must be shown by inference or presumption. State v. Williams, 324 N.W.2d 154, 160 (Minn. 1982), held that when the intent of an accused is an element of the crime, its existence is a jury issue. If certain basic facts are proved, a presumption is created that the intent existed. See id. The defendant may produce evidence to rebut the presumed connection between the basic facts and intent.

  8. State v. Schouweiler

    887 N.W.2d 22 (Minn. 2016)   Cited 12 times
    Explaining that, in construing a statute, Minnesota courts presume that the legislature does not intend absurd results

    Minn.Stat. § 609.535, subd. 3(2) (2014). We have said that the defendant must be given the opportunity to rebut such a presumption at trial, State v. Williams, 324 N.W.2d 154, 160 (Minn.1982), but we have never directly addressed the constitutionality of allowing the fact-finder to infer intent from a presumption, see id. at 160 n. 4. Schouweiler's sole contention is that her check was “given for a past consideration” and is therefore subject to the exception in the dishonored-check statute.

  9. State v. Bustos

    861 N.W.2d 655 (Minn. 2015)   Cited 71 times
    Holding it was "unnecessary to decide whether the district court abused its discretion in excluding" evidence because even if it did, "the error was harmless and does not warrant reversal"

    Jury instructions also guard against erroneous convictions by ensuring that the State establishes each element of a crime beyond a reasonable doubt. See State v. Williams, 324 N.W.2d 154, 160 (Minn.1982). When faced with an improper instruction and an improper restraint on vigorous advocacy regarding the State's burden of proof, a jury is ill equipped to determine whether the State met the burden of proving an offense beyond a reasonable doubt.

  10. State v. Vance

    734 N.W.2d 650 (Minn. 2007)   Cited 188 times
    Holding the offense severity level of an assault is determined by the resultant injury to the victim, not by the harm intended

    Id. at 85-86, 103 S.Ct. 969 (footnote omitted). See also State v. Williams, 324 N.W.2d 154, 160 (Minn. 1982) (holding that when intent is an element of the offense, the court may not withdraw the issue from the jury by instructing that the law raises a presumption of intent from an act). Yet the Supreme Court and our court have also concluded that under particular circumstances, the failure to submit an element of the offense to the jury is harmless.