State v. Williams

8 Citing cases

  1. 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.

  2. 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.

  3. 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.

  4. State v. Auchampach

    540 N.W.2d 808 (Minn. 1995)   Cited 98 times
    Holding that the state is required to prove each element of the charged crime beyond a reasonable doubt

    State v. Jones, 347 N.W.2d 796, 801 (Minn. 1984); State v. Williams, 324 N.W.2d 154, 159 (Minn. 1982). Finally, the trial court's jury instructions must adequately instruct the jury on the state's burden to prove defendant's guilt beyond a reasonable doubt.

  5. State v. LaForge

    347 N.W.2d 247 (Minn. 1984)   Cited 30 times
    Holding that jury instruction error is preserved by new trial motion under Rule 26.03, subd. 18, and that unconstitutional instruction allowing jury to presume intent cannot be deemed harmless under Connecticut v. Johnson, 460 U.S. 73, 103 S.Ct. 969, 74 L.Ed.2d 823

    In Sandstrom, however, the same general instructions were held not to have removed the potential that the jury interpreted the instructions as a mandatory presumption. 442 U.S. at 518-19 n. 7, 99 S.Ct. at 2456-57 n. 7. Moreover, in the recent Minnesota case of State v. Williams, 324 N.W.2d 154 (Minn. 1982), a lack of qualifying instructions to the effect that the jury could consider the explanation or that it could disregard the presumption was important to the finding that the instruction given was "tantamount to an irrebuttable presumption that denies due process." Id. at 160 citing Sandstrom v. Montana, 442 U.S. 510, 99 S.Ct. 2450, 61 L.Ed.2d 39 (1979).

  6. State v. Charlton

    338 N.W.2d 26 (Minn. 1983)   Cited 61 times
    Holding that defendant has initial burden of production with respect to issue of duress for specific intent crime; the burden then shifts back to the state to show lack of duress, or its converse, specific intent, because duress negates element of specific intent

    Chapman v. California, 386 U.S. 18, 24, 87 S.Ct. 824, 828, 17 L.Ed.2d 705 (1967). If a failure to appropriately instruct as a matter of fundamental law results in substantial and material prejudice to defendant, a new trial is necessary. State v. Williams, 324 N.W.2d 154, 157 (Minn. 1982). We do not believe that the erroneous instruction in this case resulted in material and substantial prejudice to the defendant.

  7. State v. Litzau

    No. C3-00-2099 (Minn. Ct. App. Nov. 20, 2001)   Cited 2 times

    "Instructions that allow the trier of fact to remain free to credit or reject inferences do not violate principles of due process." State v. Williams, 324 N.W.2d 154, 160 (Minn. 1982). In this case, the district court did not instruct the jury to make a mandatory inference.

  8. State v. Wallat

    No. C1-96-1186 (Minn. Ct. App. Apr. 22, 1997)   Cited 1 times

    Because this instruction fairly and correctly stated the applicable law, we see no error. Appellant's reliance on State v. Williams, 324 N.W.2d 154 (Minn. 1982), is misplaced. Williams reversed and remanded a defendant's conviction because the jury instruction had not included intent to defraud as an element of theft by false representation, specifically by check. Id. at 157-59.