2007-M-34
State of Minnesota, Respondent, vs. John Jason McLaughlin, Appellant.
DESCRIPTION OF CRIME: On September 24, 2003, fifteen-year-old McLaughlin brought
a handgun to Rocori High School south of St. Cloud and shot to death fellow
students Seth Bartell and Aaron Rollins. Gym teacher Mark Johnson took
the gun from McLaughlin and walked him to the office.
When the police took McLaughlin to the station, McLaughlin said
that he started thinking about bringing a gun to school approximately one week
earlier. He also said that two days before the shootings he checked the
school for metal detectors and security cameras. Toward the end of the
interview, the BCA agent asked McLaughlin, “Do you think you did something
wrong today?” McLaughlin replied, “Yeah.”
THE TRIAL: Approximately six months after the shootings, the Stearns County
Juvenile Court certified McLaughlin to stand trial as an adult.
McLaughlin appealed the certification to the Minnesota Court of Appeals, which
affirmed the certification order.
The parties then agreed to a bifurcated bench trial in which
McLaughlin would stipulate to guilt in the second-degree murder of Rollins
during the trial’s first phase and would attempt to prove a mental illness defense
during the second phase. There was no stipulation as to Bartell.
At the close of the first phase, the district court found
McLaughlin guilty of first-degree murder in Bartell’s death, second-degree
murder in Rollins’ death, and possession of a dangerous weapon on school
property.
In the second phase, the court heard testimony from six mental
health experts—three retained by McLaughlin, one by the state, and two by the
court.
After six days of testimony in the mental illness phase of McLaughlin’s
trial, the district court concluded that McLaughlin could not be excused from
responsibility for the crimes he committed because he “had cognitive awareness
that shooting the victims was morally wrong.”
At the end of a sentencing hearing that included expert testimony
on bullying, the district court imposed a life sentence for the death of
Bartell, to be served consecutively with a 144-month sentence for the death of
Rollins.
THIS APPEAL: On direct appeal, the Minnesota Supreme Court upheld McLaughlin’s
convictions and sentences.
Justice Gildea joined the unanimous decision by Justice Paul
Anderson.
First, the Minnesota Supreme Court declined to use the interests of
justice as a basis to consider defendant’s constitutional challenge to the M’Naghten
rule given the absence of a well-developed record that is relevant to the
particular issue the defendant raises for the first time on appeal.
Second, the Minnesota Supreme Court held that the district court did not
err when it denied a mid-trial continuance when the defendant failed to prove
that the court’s denial of the continuance materially affected the outcome of
his trial.
Third, the Minnesota Supreme Court held that the district court did not
abuse its discretion by imposing permissive consecutive sentences when the
court reasonably found that the aggravating and mitigating factors balanced one
another, and therefore imposed a sentence commensurate with other sentences
imposed for comparable homicides involving multiple victims.
Paul Anderson (Russell Anderson,
Page, Hanson, Meyer, Barry Anderson, and Gildea)
DATE OF DECISION: January 11, 2007
RECORD NUMBER: 2007-009
DESCRIPTION: [MURDER] [INSANITY DEFENSE]
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