State v. Hayes

Summary

The Minnesota Supreme Court affirmed Donald W. Hayes’s convictions for first-degree domestic-abuse murder and second-degree murder arising from the death of a 13-month-old child. The court held that the evidence was sufficient to establish an intentional assault causing death and a past pattern of domestic abuse, and that the jury instructions did not improperly omit requirements concerning proof of prior acts or unanimity regarding the specific acts constituting the pattern.

Holdings

1. The evidence was sufficient to prove beyond a reasonable doubt that Hayes caused Robert’s death while committing an intentional assault.
2. The evidence was sufficient to establish that Hayes had engaged in a past pattern of domestic abuse for purposes of first-degree domestic-abuse murder.
3. The district court did not plainly err by failing to give a separate instruction stating that at least two prior acts of domestic abuse had to be proven beyond a reasonable doubt.
4. The jury was not required to unanimously agree on which specific acts comprised the past pattern of domestic abuse.

Questions Presented

1. Whether the evidence was sufficient to prove that Hayes intentionally assaulted Robert and caused his death.
2. Whether the evidence was sufficient to prove that Hayes had engaged in a past pattern of domestic abuse.
3. Whether the district court plainly erred by failing to instruct the jury that the State had to prove at least two prior acts of domestic abuse beyond a reasonable doubt.
4. Whether the district court plainly erred by failing to instruct the jury that it had to unanimously agree on which specific acts constituted the past pattern of domestic abuse.

Disposition

affirmed