Another Appeal of a Home Invasion at a Drug Dealers' Apartment in St. Paul

2006-M-18          State of Minnesota, Respondent, vs. Michael Medal-Mendoza, Appellant.

DESCRIPTION OF CRIME:  On January 12, 2004, drug dealers Andria Rai Crosby, Ronald Edward Glasgow and Wayne Louis Costilla sold methamphetamine to Michael Medal-Mendoza, James Green, and Danny Valtierra at Costilla’s apartment in St. Paul.  The three buyers left, saying they were going to sell the drugs to someone else.

Thirty minutes later, Medal-Mendoza, Green, and Valtierra returned to Costilla’s apartment to rob the occupants.  Medal-Mendoza shot Glasgow in the head, killing him.  Someone shot Crosby in the chest and legs.   Someone shot and killed Costilla.

Crosby recognized Green as a high school class-mate and identified him from a school year-book.  An informant identified Medal-Mendoza and Valtierra as Green’s accomplices in the shootings and the robbery.

THE TRIAL:  A Ramsey County jury convicted Medal-Mendoza of six felony counts related to the shootings.  Medal-Mendoza was then convicted and sentenced to two consecutive terms of life in prison for two first-degree murder convictions and to a consecutive term of 180 months in prison for an attempted first-degree murder conviction. 

THIS DECISION:  Justice Gildea voted with Justice Helen Meyer’s unanimous opinion that upheld Medal-Mendoza’s convictions and sentences.

On direct appeal to the Supreme Court, Medal-Mendoza argued that the district court committed prejudicial error during his trial because (1) the court violated Medal-Mendoza’s right to present a defense by not allowing him to present evidence of his codefendants’ gang affiliation with each other and with a third person; (2) the court improperly allowed a police officer to testify as an expert regarding “triangulation” evidence; and (3) the court instructed the jury that it could consider Medal-Mendoza’s flight as proof of his guilty intent.  In his pro se supplemental brief, Medal-Mendoza additionally claimed that he was deprived of his right to confront his accusers because the state introduced evidence that was provided by a confidential informant.  He also claims ineffective assistance of trial counsel.

First, the Supreme Court held that the district court did not violate defendant’s right to present a defense by prohibiting the defendant from introducing evidence of his codefendants’ gang affiliation with each other and with a third person where the defendant failed to lay a proper foundation to establish that the evidence had an inherent tendency to connect the third person to the commission of the charged crime. 

Second, the Supreme Court held that the district court erred by allowing expert police testimony on “triangulation,” but the error did not substantially influence the jury’s decision and does not warrant a new trial where the defendant’s guilt was independently supported by strong evidence.

Third, the Supreme Court held that the district court erred by instructing the jury that defendant’s guilty intent could be inferred if the jury determined that defendant fled, but the error had no significant impact on the verdict where the defendant’s guilt was independently supported by strong evidence and the particular evidence of flight was rebutted by other evidence. 

Fourth, the Supreme Court held that the district court did not deprive the defendant of his right to confront his accusers, and the defendant’s claim of ineffective assistance of counsel is without merit.

DATE OF DECISION:  August 3, 2006

RECORD NUMBER:  2006-136

FULL OPINION:  A05-1084,

DESCRIPTION:  [MURDER]  [ROBBERY] [DRUGS]