2006-M-24 State
of Minnesota, Respondent, vs. Eric Maurice Wright, Appellant.
DESCRIPTION OF CRIME: On March 24, 2004, Wright stabbed to death the 82-year-old
father of his girl-friend, Raymond Wander, in his El Rosa home in Stearns
County. A crack addict who lived with Wander’s daughter in Richfield in
Hennepin County, Wright was in the midst of a three-day binge of crack
consumption and repeated suicide attempts. Wright’s DNA was tied to the
crime scene with a number of pieces of evidence analyzed by the Minnesota
Bureau of Criminal Apprehension.
THE TRIAL: A Stearns County jury found Wright guilty of first-degree
premeditated murder, several counts of first-degree felony murder, and
second-degree murder. The district court entered judgment of
conviction for first-degree premeditated murder and imposed a life prison term
without the possibility of release.
THIS APPEAL: On direct appeal, Wright challenges: 1) the
admission of other-crimes evidence; 2) deprivation of his right to a fair trial
by engaging in prejudicial misconduct during the opening statement and closing
argument; 3) the legality of his sentence to a life prison term without the
possibility of release; and 4) deprivation of his right to effective assistance
of counsel.
Justice Gildea joined the unanimous decision by Chief Justice
Russell Anderson on this direct appeal to uphold Wright’s conviction and
sentence.
First, the Minnesota Supreme Court upheld the trial court’s admission of
other-crimes evidence.
In 1991, Wright was charged with attempted second-degree
murder and first-degree criminal sexual conduct. He ultimately entered a
guilty plea to first-degree assault and was sentenced to a 180-month prison
term. During the trial for the current offense, the factual-basis inquiry
portion of the 1991 plea-hearing transcript was read to the jury.
Here, the district court determined that the prior assault had
sufficient similarities to the charged offense to be relevant to the issue of
identity: both incidents involved intrusions into homes of vulnerable victims
whom Wright had known for some time; both incidents occurred in the early
morning hours; both incidents were preceded by extensive drug use; and the
weapon used and injuries inflicted in both incidents were markedly
similar. Wright correctly points out that the Spreigl offense
occurred 13 years prior to the charged offense and that the incidents occurred
in two different cities located 2 hours apart. But temporal-remoteness
concerns were considerably reduced by Wright’s extensive incarceration between
the two offenses; and circumstances of the prior offense were sufficiently
similar to the charged offense.
Second, the Minnesota Supreme Court upheld the trial court’s decision
that the prosecutor had not deprived him of his right to a fair trial by
engaging in prejudicial misconduct during the opening statement and closing
argument.
It is not misconduct for the state to analyze the evidence and
argue that particular witnesses were or were not credible.
Examined in context, the prosecutor’s remarks related to Wright’s
intoxication defense had more to do with the merits of that defense and were
not aimed at improper disparagement.
Third, the Minnesota Supreme Court upheld the trial court’s decision to
sentence Wright to a life prison term without the possibility of release.
Under Minnesota law, a conviction for first-degree premeditated
murder is punishable by a term of life in prison. A defendant convicted
of first-degree premeditated murder who has “one or more previous convictions
for a heinous crime” shall be sentenced to life without possibility of
release. Heinous crimes include “a violation of section 609.221
[first-degree assault].
Because Wright had a prior conviction for first-degree assault, he
was sentenced to life without possibility of release. Wright asserts that
this sentence violated Apprendi. Apprendi holds that
“[o]ther than the fact of a prior conviction, any fact that increases the
penalty for a crime beyond the prescribed statutory maximum must be submitted
to a jury, and proved beyond a reasonable doubt.” Apprendi
has no application to a mandatory life sentence with a release disqualifier
based on a prior conviction.
Fourth, the Minnesota Supreme Court rejected Wright’s claim that he was
deprived of his right to effective assistance of counsel.
The record reflects that trial counsel proceeded reasonably; and
much of trial counsel’s approach that Wright now claims was inadequate relates
to trial tactics. What evidence to present and which witnesses to call at
trial are tactical decisions properly left to the discretion of trial counsel.
Wright was not denied effective assistance of counsel.
DATE OF DECISION: August 17, 2006
RECORD NUMBER: 2006-150
DESCRIPTION: [MURDER] [ROBBERY]
No comments:
Post a Comment