Don't go into the house of a gang who robbed you five months ago.  They will burn you!

2017-M-350  State of Minnesota, Respondent, vs. Manuel Guzman, Appellant.

BACKGROUND:  Guzman and his friends robbed the friend of Rufino Clara-Rendon in the spring of 2014.  On August 7, 2014, Guzman called Rufino a “snitch” during a confrontation in front of Guzman’s home.  Faced by five men who had threatened him, a terrified Rufino agreed to follow the group into the house.  Guzman fatally shot Rufino through the forehead.  The group hauled the body to an alley and burned it.

Following deliberations, the jury found appellant guilty of first-degree premeditated murder, and the district court sentenced him to life imprisonment without the possibility of release. On appeal, appellant contends that the district court committed reversible error in its pretrial and evidentiary rulings, as well as in its instructions to the jury.

HELD:  The Supreme Court dealt with a number of claims, and then affirmed Guzman’s conviction and sentence.

The district court did not err when it denied appellant’s pre-trial motion to quash the indictment.

The district court did not abuse its discretion when it denied appellant’s pretrial motion to disclose the entire grand jury transcript.

The district court did not violate appellant's right to present a defense when it excluded reverse-Spreigl evidence on the grounds that it was inadmissible under the rules of evidence governing relevancy, unfair prejudice, hearsay, and impeachment.

The district court's admission of evidence regarding appellant’s incarceration for an unrelated offense was harmless.

 The district court did not plainly err when it allowed a witness to testify on redirect examination that during one of the recorded calls between appellant and his girlfriend, appellant was talking in code about selling a gun.

Any alleged error in the district court’s jury instructions was harmless. Affirmed.

Anderson (Gildea, Stras, Lillehaug, Hudson, Chutich, and McKeig)

Date: April 12, 2017

[CRIME] [MURDER] [PREMEDITATED] [FIRST-DEGREE]

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Demographic Information**

MNDOC Offender ID:

246712

Name:

Manuel Guzman

Birth Date:

06/05/1990

Current Status:

Incarcerated as of 04/10/2015. Currently at MCF Rush City.

Sentence Date:

04/10/2015

Anticipated Release Date:

Life without Parole

Expiration Date:

Life

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