2012-M-221           State of Minnesota, Respondent, vs. Alfunda Scruggs, Appellant.

A Hennepin County jury found appellant Alfunda Scruggs guilty of first-degree premeditated murder and second-degree intentional murder arising out of the February 4, 2010, death of Michael Fonta by strangulation.  The district court entered judgment of conviction on the first-degree murder charge and imposed a life sentence without the possibility of release.

 In this direct appeal, Scruggs argues that the court erred in:  (1) denying his motion to suppress his statement to police on the basis that it was obtained in violation of his Miranda rights; (2) refusing to instruct the jury that Scruggs’s girlfriend, H.J., was an accomplice as a matter of law; (3) failing to instruct the jury on the aiding-and-advising theory of accomplice liability; (4) admitting evidence of Scruggs’s prior assaults of H.J.; and (5) various other issues raised by Scruggs in his pro se brief.  We affirm.

 

HELD:  First, the district court did not err in denying appellant’s motion to suppress his statement to the police because the appellant was not in custody when he made the statement, and therefore a Miranda warning was not required.

Second, because the facts did not compel a single inference regarding whether a witness was an accomplice, the district court did not err when it denied appellant’s request to instruct the jury that the witness was an accomplice as a matter of law.

Third, the district court did not commit plain error when it instructed the jury that a conviction could not be based on the uncorroborated testimony of an accomplice without specifically instructing the jury on when a person could be liable for a crime committed by another as an aider and advisor under Minn. Stat. § 609.05, subds. 1-2 (2010).

Fourth, the district court did not abuse its discretion when it admitted Spreigl evidence regarding the appellant’s prior assaults of a witness.

Affirmed.

Dietzen (Gildea, Page, Paul Anderson, Barry Anderson, Stras, and Wright)

Took no part:  Wright

[MURDER]