State v. Williams
2009 WL 2778203, 2009 Minn. LEXIS 585, 771 N.W.2d 514 (2009)
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Rule of Law:
A district court does not abuse its discretion by allowing impeachment with prior felony convictions under the 'whole person' test if the `Jones` factors weigh for admissibility, nor does it err in applying the `Hernandez` method to increase a criminal-history score for a felon-in-possession conviction sentenced on the same day as another offense arising from the same behavioral incident, as the Sentencing Guidelines do not expressly prohibit this for all statutory exceptions.
Facts:
- On the afternoon of September 14, 2006, Minneapolis police responded to a 911 call reporting a shooting in South Minneapolis.
- A responding officer found Bennie Hodges shot and lying on his stomach; Hodges identified Antoine Delany Williams (nicknamed 'Little Cuz') as the shooter.
- The next day, Hodges identified Williams in a photographic lineup, and Hodges' mother independently identified Williams as the shooter in a separate lineup.
- A next-door neighbor, who had witnessed the shooting, described the shooter as an African-American male, 25-30 years old, with braids and facial hair, matching Williams's description.
- Williams was charged with first-degree assault, second-degree assault, attempted first-degree aggravated robbery, and felon in possession of a firearm.
- V.R., a friend of Williams, testified that Williams called her from a Subway restaurant that afternoon and she picked him up to watch television at her house.
Procedural Posture:
- In March 2007, Antoine Delany Williams was convicted by a district court jury of first-degree assault, second-degree assault, and possession of a firearm by a felon.
- The district court imposed a 60-month sentence for the firearm conviction, which increased Williams’s criminal-history score, and then imposed the maximum presumptive sentence of 160 months for first-degree assault, to be served concurrently.
- Williams appealed the convictions and sentence to the Minnesota Court of Appeals, arguing errors in impeachment and sentencing.
- The Minnesota Court of Appeals affirmed the district court's decision, concluding there was no abuse of discretion regarding impeachment and that the felon-in-possession offense could be sentenced first and included in the criminal-history score.
- Williams then sought review from the Minnesota Supreme Court, which granted review.
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Issue:
1. Did the district court abuse its discretion by ruling that the State could impeach Antoine Delany Williams with his prior drug-related felony convictions if he chose to testify? 2. Did the district court err in applying the `Hernandez` method by including Antoine Delany Williams's felon-in-possession conviction in his criminal-history score before sentencing him on his first-degree assault conviction, when both offenses arose from the same behavioral incident?
Opinions:
Majority - Dietzen, Justice
1. No, the district court did not abuse its discretion in ruling that the State could impeach Antoine Delany Williams with two prior drug-related felony convictions if he chose to testify. The court reviews a district court’s decision to admit evidence of prior convictions for an abuse of discretion under Minn. R. Evid. 609(a)(1), which requires that the probative value of the evidence outweighs its prejudicial effect. The `Jones` factors guide this determination. First, the district court properly applied the 'whole person' test, concluding the convictions helped the jury see Williams’s 'whole person' to better judge his truthfulness, a sound rationale established in `State v. Brouillette`. The court declined to abrogate this test as Rule 609 already provides safeguards against prejudice. Second, the recency of Williams's prior convictions (less than two years before trial) and their pattern of lawlessness favored admissibility. Third, the prior drug-related convictions were dissimilar to the violent charged crimes, reducing the risk of the jury using them substantively. Fourth, the importance of Williams's testimony did not favor exclusion because his theory of the case was presented through another witness (V.R.), and he made no offer of proof for additional testimony, consistent with `State v. Gassier`. Finally, the centrality of the credibility issue favored admissibility, as the identity of the perpetrator was a central dispute. Thus, the district court properly weighed the `Jones` factors and did not abuse its discretion. 2. No, the district court did not err in applying the `Hernandez` method by including Antoine Delany Williams's felon-in-possession conviction in his criminal-history score before sentencing him on his first-degree assault conviction. The interpretation of statutes and sentencing guidelines is reviewed de novo. Minn. Stat. § 609.035, subd. 1, generally prohibits multiple sentences for offenses arising from a single behavioral incident, but it contains exceptions, including felon-in-possession-of-a-firearm offenses. The `Hernandez` method allows a conviction for which a defendant is first sentenced to be added to their criminal-history score for another offense sentenced on the same day. The Minnesota Sentencing Guidelines (Minn. Sent. Guidelines II.B.l.c) specifically prohibit the `Hernandez` method for certain enumerated exceptions (methamphetamine-related, burglary, kidnapping) when multiple current convictions arise from a single course of conduct. Applying the canon `expressio unius est exclusio alterius` ('the expression of one thing is the exclusion of another'), the court concluded that because the guidelines only prohibit the `Hernandez` method for the specifically listed exceptions, they do not prohibit its application to the felon-in-possession exception under § 609.035, subd. 3. The court noted that the Sentencing Guidelines Commission's deliberations over the years indicate a deliberate choice not to extend this prohibition to the felon-in-possession exception. The court declined Williams's invitation to create such a prohibition, stating that this function properly belongs to the Commission.
Analysis:
This case clarifies the application of Minnesota's rules on impeachment by prior convictions and sentencing for multiple offenses arising from a single behavioral incident. It reinforces the 'whole person' test for assessing the impeachment value of prior crimes, providing guidance on how courts should weigh the `Jones` factors to balance probative value against prejudice. More significantly, it affirms judicial restraint in interpreting sentencing guidelines, emphasizing that unless the Sentencing Guidelines Commission explicitly prohibits the `Hernandez` method for specific statutory exceptions (like felon-in-possession), courts may continue to apply it. This outcome highlights the distinct roles of the legislature in defining crimes, the Commission in setting sentencing guidelines, and the judiciary in applying them, limiting judicial expansion of guideline prohibitions.
