State v. Buckingham

Summary

The Minnesota Supreme Court reviewed Justin Lamont Buckingham's convictions for aiding and abetting first-degree murder and attempted first-degree murder arising from a drive-by shooting. The court rejected challenges concerning custodial-interrogation recording, contact with Buckingham without counsel, sufficiency of the evidence, and prosecutorial misconduct. It affirmed the convictions and modified the sentences for attempted first-degree drive-by shooting murder from 243 months to the statutory maximum of 240 months.

Holdings

1. Any failure to record Buckingham's custodial interrogation was not a substantial violation of State v. Scales and therefore did not require suppression of the statements.
2. Buckingham's statements were not obtained through improper police contact requiring suppression.
3. The evidence was sufficient for a reasonable jury to find Buckingham guilty of aiding and abetting first-degree murder.
4. The statutory maximum sentence for each attempted first-degree drive-by shooting murder conviction was 240 months, not 243 months; the sentences were reduced accordingly.
5. The prosecutor's challenged gang-related statements did not constitute reversible plain error.

Questions Presented

1. Whether Buckingham's police statements should be suppressed because the interview was not recorded in violation of State v. Scales.
2. Whether Buckingham's statements should be suppressed because police interviewed him without his attorney present or consent.
3. Whether the evidence was sufficient to prove that Buckingham aided and abetted first-degree murder and attempted first-degree murder.
4. Whether the sentences of 243 months for attempted first-degree drive-by shooting murder exceeded the statutory maximum.
5. Whether unobjected-to prosecutorial statements concerning gang-related threats constituted plain prosecutorial misconduct requiring relief.

Disposition

affirmed