State v. St. Christopher
1975 Minn. LEXIS 1318, 232 N.W.2d 798, 305 Minn. 226 (1975)
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Rule of Law:
Under the Minnesota conspiracy statute, a defendant can be convicted of conspiracy even if the only other person with whom they conspired feigned agreement and never intended to commit the crime.
Facts:
- Daniel St. Christopher told his cousin, Roger Zobel, that he wanted to kill his mother and asked for Zobel’s help.
- St. Christopher offered to pay Zobel $125,000 from an anticipated inheritance after his mother was dead.
- From the outset, Zobel never intended to participate in the murder and only feigned his agreement with the plan.
- Zobel immediately contacted the police and was instructed to continue cooperating with St. Christopher.
- A plan was developed for Zobel to go to the family farmhouse, break the mother’s neck, and dispose of the body.
- As part of the plan, St. Christopher feigned car trouble and called his father for help, which was the pre-arranged signal for Zobel to proceed.
- In a phone call recorded by police, St. Christopher told Zobel that his father was on his way and that Zobel should proceed with the murder.
- Immediately after this call, police arrested St. Christopher.
Procedural Posture:
- The State of Minnesota charged Daniel St. Christopher with conspiracy to commit murder.
- The case was tried in a state trial court before a judge, sitting without a jury.
- The trial court found St. Christopher guilty of both conspiracy to commit murder and attempted first-degree murder.
- The court sentenced St. Christopher to a maximum of 20 years’ imprisonment based on the conspiracy conviction.
- St. Christopher (appellant) appealed the judgment to the Minnesota Supreme Court.
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Issue:
Does a person commit the crime of conspiracy under Minnesota law if the only other party to the alleged agreement feigned their intent to participate while secretly cooperating with the police?
Opinions:
Majority - Rogosheske, Justice.
Yes. A person can be convicted of conspiracy under Minnesota law even if their only co-conspirator feigned agreement. The court rejected the traditional bilateral approach to conspiracy, which requires a true 'meeting of the minds' between at least two guilty parties. Instead, the court adopted the unilateral approach, which focuses on the individual culpability of the defendant. The court reasoned that a defendant who believes they are conspiring to commit a crime has a guilty mind and has done everything in their power to plot the crime, making the secret intentions of the other party irrelevant. This decision is grounded in the specific wording of Minnesota’s current conspiracy statute (§ 609.175, subd. 2), which reads 'Whoever conspires with another,' focusing on the individual actor, unlike the older statute which read 'When two or more persons shall conspire,' implying a bilateral agreement. The court also reversed the attempted murder conviction, holding it is not a lesser included offense of conspiracy because attempt requires a 'substantial step' toward the crime's commission, whereas conspiracy only requires an agreement and any overt act, however slight.
Analysis:
This decision officially moves Minnesota conspiracy law from the traditional bilateral theory to the modern unilateral theory, as advocated by the Model Penal Code. It establishes that the focus of a conspiracy charge is on the individual defendant's criminal intent and agreement, not on the existence of a genuinely shared criminal purpose between two or more people. This significantly strengthens the ability of prosecutors to bring conspiracy charges in cases involving undercover officers or informants, as the informant's feigned agreement no longer provides a defense. The case underscores the critical role of statutory language in shaping criminal doctrine, as the court's holding was decisively based on the legislature's shift from plural ('two or more persons') to singular ('Whoever conspires') phrasing.
