Monday, September 18, 2017

Do not tell the police that you only stabbed the victim once and that was just to calm her down!

2015-M-274           State of Minnesota, Respondent, vs. Patrick William Benton, Appellant.


THE CRIME:  Benton and Susan Courteau met at a detox facility in February 2011, and their
relationship became intimate soon thereafter.  In September 2011 Courteau told her apartment manager that Benton would be at the apartment helping with chores while she was on house arrest following a DWI probation violation.  Courteau’s sister felt that Benton’s presence threatened Courteau’s sobriety. 

On October 11, 2011, Courteau told her sister that Benton was keeping alcohol in her apartment, which made Courteau nervous and upset.  When the sister came to the apartment to help Courteau confront Benton, she found Benton inebriated on Courteau’s bed.  The sister told Courteau she should call the police to remove Benton from the apartment.  But the next day Benton
still refused to leave the apartment, and Courteau did not call the police.

On October 13, 2011, the day Courteau died, the apartment manager saw Benton with a dog.  She called Courteau to tell her that the apartment complex did not allow dogs.  Courteau told the manager that the dog belonged to Benton and that she was afraid of Benton and wanted him to leave.  After the manager asked Benton to leave and he refused, the manager called the police.  That same morning, the police removed Benton from the apartment and drove him to his sister’s home. 

Benton and his sister spent the day together and got “pretty drunk.”  Later that day, Benton and Courteau spoke on the phone, and Benton became angry when Courteau told him the relationship was over and she had put all of his belongings in her garage.  Benton went to Courteau’s apartment.  He collected his belongings and was seen around Courteau’s apartment complex as late as 6:00 p.m. on the night of the murder.

When Courteau’s sister had not heard from Courteau later that day, she went to the apartment.  The door was locked, but through the door crack she saw Courteau’s legs and feet lying on the ground.  She got the manager to open the door and found Courteau lying on her back with blood on her face and arms.  She had been stabbed six times in her back and chest and three times in her arms.

Benton was arrested early the next morning.  He initially told the police that he had not hurt or killed Courteau, and that on the night of Courteau’s death he had spoken to her only briefly at her apartment.  The next day he admitted to going into her apartment, but said that Courteau had stabbed herself in a suicide, and he stabbed her only once “to settle her down.”  Benton was indicted for first-degree premeditated murder, and first-degree domestic-abuse murder, and was also charged with two counts of second-degree murder,

THIS APPEAL:  Appellant Patrick William Benton was convicted of first-degree domestic-abuse murder, and two counts of second-degree murder, for the 2011 death of Susan Courteau.  Benton presents two questions on direct appeal:  (1) whether a criminal defendant is entitled to relief based on an alleged violation of his Sixth Amendment right to a public trial when the defendant requests the courtroom closure; and (2) whether the district court erred by admitting relationship evidence.  We affirm.

1. A criminal defendant is not entitled to relief based on an alleged violation of his Sixth Amendment right to a public trial when the defendant requested the courtroom closure and the alleged error does not seriously affect the fairness, integrity, or public reputation of the judicial proceedings.

2. The allegedly erroneous admission of relationship evidence under Minn. Stat. § 634.20 (2014) was harmless because it did not significantly affect the verdict.   3. Appellant’s pro se arguments lack merit.

Affirmed.

               Barry Anderson (Gildea, Page, Dietzen, Stras, Wright, and Lillehaug)
[MURDER]

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