2006-M-08 State
of Minnesota, Respondent, vs. Brett Arnold Laine, Appellant.
DESCRIPTION OF THE CRIME: In earlier years, Brett Laine had established a pattern of
domestic violence. He had violently beaten his first ex-wife several
times. On one occasion, Laine had threatened to kill her, thrown
her around the living room, and pinned her head against a cement wall with his
forearm. She further testified that he had physically abused her on
other occasions. Laine’s second wife testified that Laine assaulted her on many occasions
during their marriage. On one occasion, he beat her with her high heel shoe. On
another, Laine picked up the barstool on which she was sitting and slammed her
and the barstool to the floor. As a result of this latter incident, Laine pleaded guilty to
assault.
On October 1, 2003, Laine called police at 3:20 a.m. to
report that his girlfriend Nancy Jagunich had fallen down a staircase at 1:00
a.m. He told police that she was not breathing. Emergency
responders were unable to resuscitate Jagunich, and she was pronounced dead at
approximately 4:00 a.m.
Laine told responding officers that Jagunich had fallen and had
not regained consciousness after her fall. He denied that he and Jagunich
had any arguments that night. Laine told officers that after Jagunich fell he
took her to the lower level of the home, undressed Jagunich and himself, and
laundered both sets of clothes. He also cleaned the blood from the landing at
the bottom of the stairs. He told officers that when Jagunich developed breathing
difficulties he called his mother, who lived nearby, and then called for an
ambulance. Officers noticed red stains, Jagunich’s glasses, and what appeared to be
multiple strands of human hair in the upper level of the home, but Laine told
them that he had not brought Jagunich upstairs after her fall.
When asked about the cause of lacerations and bruising on Jagunich’s face,
Laine told officers the injuries were a result of the fall. Officers noticed a
cut across the bridge of Laine’s nose; Laine claimed that he had received that cut the day before
while riding his all-terrain vehicle.
APPELLATE HISTORY: Laine was convicted of first-degree domestic abuse
murder. He was sentenced to life imprisonment. Laine
directly appealed his conviction to this court, and we later granted Laine’s
motion to stay his direct appeal while he pursued post-conviction relief. After
the post-conviction court denied Laine’s petition for post-conviction relief
without an evidentiary hearing, we granted Laine’s motion to lift the stay on his
direct appeal.
THIS DECISION: Justice Gildea joined the opinion of Justice Barry
Anderson. Laine had requested a reversal of his conviction based on
insufficient evidence. In the alternative, alleging error on several grounds, Laine
sought a new trial. Because sufficient evidence sustained the murder conviction
and there was no error warranting a new trial, the Supreme Court upheld both
his conviction and his sentence.
First, the Supreme Court held that the evidence was sufficient to
sustain the verdict.
“When reviewing the sufficiency of evidence, we inquire whether,
given the facts in the record and any legitimate inferences that can be drawn
from those facts, a jury could reasonably find that the defendant was guilty of
the charged offense. We view the evidence in the light most favorable to the verdict. A
conviction based on circumstantial evidence will stand only if the
circumstantial evidence forms ‘a complete chain which, in light of the evidence as a whole, leads
so directly to the guilt of the accused as to exclude, beyond a reasonable
doubt, any reasonable inference other than that of guilt.’ When
applying this standard, however, it remains the province of the jury to
determine the credibility and weight of the circumstantial evidence and we will
continue to assume the jury believed the state’s witnesses and disbelieved the
defendant’s witnesses.
“To convict Laine of first-degree domestic abuse murder, the state
must prove that Laine: (1) caused the death of Jagunich, (2) that Jagunich’s death
occurred while Laine was committing domestic abuse, (3) that Laine had engaged
in a past pattern of domestic abuse upon Jagunich or upon another family or
household member, and (4) Jagunich’s death occurred ‘under
circumstances manifesting an extreme indifference to human life.’
Laine appears to argue that the state failed its burden of proof on the
first, second, and fourth elements.”
“Viewing the evidence in the light most favorable to the verdict,
there is strong evidence supporting the verdict. While Laine argues, there is ‘insufficient
proof’ that he caused Jagunich’s death, the testimony of the medical
examiner demonstrates otherwise. The medical examiner testified that
the cause of Jagunich’s death was multiple blunt traumas to the head that cumulatively
caused her death. He further testified that this trauma was a type of injury
that could be inflicted by a person’s fist or forearm. While he admitted on
cross examination that a fall down the stairs in question could cause head
trauma, the medical examiner opined that Jagunich’s fatal injuries could not have been
caused by such a fall because of the number of severe traumas present and the
number of directions from which these traumas were inflicted. In
addition, the evidence, including Laine’s testimony, showed that Laine was
alone with Jagunich at the time she was injured. Given this evidence and given
that Laine does not dispute the evidence that Jagunich was a ‘family
or household member,’ the
circumstantial evidence excludes, beyond a reasonable doubt, any reasonable
inference other than that Laine caused Jagunich’s death while committing domestic
abuse and that Jagunich’s death occurred under circumstances manifesting an extreme
indifference to human life.
Therefore, sufficient evidence supports Laine’s
conviction.
Second, Laine claimed he was entitled to a new trial based on the
district court’s instruction to the jury concerning the state’s burden
of proof on the ‘past pattern of domestic abuse’ element of first-degree domestic
abuse murder. Laine argued that we should re-examine our prior holdings and
hold that an instruction that does not require the state to prove each incident
of prior domestic abuse beyond a reasonable doubt is erroneous. The
state argues that there is no reason to overturn this court’s
precedent on this issue and that Laine is not entitled to a new trial because
he cannot establish plain error.”
The Supreme Court held that the trial court’s jury instruction was
an accurate and previously-upheld statement of the law. On this basis,
the Supreme Court rejected Laine’s claim on this point.
Third, Laine sought a new trial because, before trial, Laine moved the
district court to grant him a bifurcated trial in which the jury would not hear
evidence regarding his past pattern of domestic abuse until the jury found that
the state had met its burden of proof on the other elements of first-degree
domestic abuse murder. Noting Laine’s failure to cite authority supporting his request, the district
court denied the motion for bifurcation. On appeal, Laine argues that ‘it was
prejudicial error to deny the defense motion to bifurcate.’ The
parties agree that, assuming a district court does have this authority, the
district court’s decision not to bifurcate a first-degree domestic abuse murder
trial would be reviewed for abuse of discretion. There is nothing in the record
to suggest that the district court abused its discretion in denying Laine’s
motion to bifurcate his trial.
Fourth, Laine claimed that the trial court’s jury instruction about his
pattern of previous domestic violence was erroneous. The Supreme Court
noted that Laine’s lawyer assisted in drafting the instruction and did not
object to the instruction, thus waiving his appellate objection.
The Supreme Court went further and held that the challenged jury
instructions, when read as a whole, correctly stated the law in language that
could be understood by the jury. Laine’s second wife (as well as Laine himself) testified that Laine had
previously pled guilty to assaulting her during their marriage. The
challenged jury instruction correctly described the purpose for which the jury
could use this evidence, as well as the other evidence of a past pattern of
domestic abuse. While Laine argues, the instruction can be read to weaken
the presumption of innocence and the state’s burden of proof, the jury was
instructed on the presumption of innocence as well as the state’s burden
of proof beyond a reasonable doubt. Moreover, Laine has not cited
any authority to support his argument that this instruction is erroneous. Because,
when read as a whole, the jury instructions correctly stated the law in a
manner the jury could understand, the challenged instruction was not erroneous.
Fifth, Laine claimed that the trial judge should not have answered the
jury’s mid-deliberation question on whether the jury had to file five separate
“guilty/not guilty” forms for lesser offenses if they jury found Laine was
guilty of first- or second-degree murder. The Supreme Court rejected this
claim.
Sixth, Laine argued that the verdicts in this case were legally
inconsistent. Laine bases this argument on the fact that, while the jury found
him guilty of first-degree domestic abuse murder, it acquitted him
of second-degree felony murder (with an underlying felony of assault). But,
as the state points out, even if this verdict is logically inconsistent, we
recently held that this type of inconsistency does not entitle a defendant to
relief.
Generally, a defendant who is found
guilty of one count of a two-count indictment or complaint is not entitled to
[relief] simply because the jury found him not guilty of the other count, even
if the guilty and not guilty verdicts may be said to be logically inconsistent.
In Leake, a case in which the
jury had found the defendant guilty of first-degree premeditated murder and
acquitted him of second-degree intentional murder, we held the verdicts were
not legally inconsistent ‘[because the case involves only logical inconsistencies ‘between
a verdict of acquittal on one count and a verdict of guilty on another count. Leake
controls this issue and the jury verdicts in this case were not legally
inconsistent.
DATE OF DECISION: June 8, 2006
RECORD NUMBER: 2006-102
DESCRIPTION: [MURDER] [DOMESTIC]
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