State of Minnesota v. Antoine Rumel Little

Summary

The Minnesota Supreme Court held that when the State adds a new charge after a defendant has waived a jury trial, the district court must obtain a renewed, personal waiver for the added charge. The court concluded that defense counsel’s reference to an earlier waiver did not satisfy Minnesota Rule of Criminal Procedure 26.01 and that the error was plain, prejudicial, and affected the fairness and integrity of the proceedings. The court reversed the court of appeals, vacated the first-degree criminal sexual conduct conviction, and remanded for further proceedings.

Holdings

1. When the State amends a criminal complaint after a defendant has waived a jury trial, the district court must obtain a renewed waiver of the defendant's right to a jury trial on the newly added charge.
2. Defense counsel's statement that a record had been made of Little's earlier waiver did not satisfy Minnesota's requirement that the defendant personally waive the right to a jury trial in writing or on the record in open court.
3. The district court's failure to obtain a personal jury-trial waiver on the added first-degree charge was plain error affecting Little's substantial rights, and reversal was required to protect the fairness and integrity of the judicial proceedings.

Questions Presented

1. Whether a defendant who has waived a jury trial must personally renew that waiver when the State later amends the complaint to add a new criminal charge.
2. Whether defense counsel's statement that a prior jury-trial waiver had been placed on the record satisfies the personal-waiver requirement for the newly added charge.
3. Whether the district court's failure to obtain a renewed personal waiver constituted plain error affecting Little's substantial rights and requiring relief.

Disposition

reversed_and_remanded