State v. Murphy

Summary

The Minnesota Supreme Court affirmed Marshall Donald Murphy's first-degree murder conviction. The court held that his confession to his probation officer was admissible under article I, section 7 of the Minnesota Constitution, applying the United States Supreme Court's interpretation of the parallel federal privilege against compelled self-incrimination. The court also upheld the sufficiency of the evidence establishing rape and felony murder, the refusal to submit third-degree murder as a lesser-included offense, and the trial court's supplemental jury instruction defining “while.”

Holdings

1. The interpretation adopted by the United States Supreme Court for the federal privilege against compelled self-incrimination also correctly states Minnesota law under article I, section 7; Murphy's confession was therefore not inadmissible on the state constitutional ground.
2. The evidence was sufficient to support the rape predicate, or at least attempted rape with force or violence, required for first-degree felony murder.
3. A killing occurring immediately after the rape to conceal the crime was part of the same continuous criminal act and satisfied the statutory requirement that the killing occur "while" the predicate felony was being committed.
4. The trial court properly refused to submit third-degree murder because the evidence did not provide a rational basis for acquittal of first-degree felony murder and conviction of third-degree murder.
5. The trial court did not commit prejudicial error by responding to the jury's question that "while" meant the defendant's acts were part of one continuous criminal act.

Questions Presented

1. Whether Murphy's confession to his probation officer was inadmissible under article I, section 7 of the Minnesota Constitution, despite the United States Supreme Court's determination that it was not compelled under the Fifth Amendment.
2. Whether the evidence was sufficient to prove rape or attempted rape as the predicate felony for first-degree felony murder.
3. Whether the evidence was sufficient to prove that the killing occurred "while" Murphy was committing or attempting to commit rape.
4. Whether the trial court erred by refusing to submit third-degree murder as a lesser-included offense.
5. Whether the trial court's supplemental instruction defining "while" as part of one continuous criminal act denied Murphy a fair trial.

Disposition

affirmed