State of Minnesota v. Elsa E. Segura

Syllabus

1. Although the State presented sufficient circumstantial evidence to sustain defendant's convictions for both first-degree felony murder while committing a kidnapping and kidnapping to commit great bodily harm or terrorize, under an aiding-and-abetting theory of liability, it failed to present sufficient evidence to sustain defendant's convictions for first-degree premeditated murder and attempted first-degree premeditated murder, under an aiding-and-abetting theory of criminal liability. 2. Defendant is not entitled to a new trial based on her unobjected-to claim of prosecutorial misconduct because the State proved that any error committed by the prosecutor did not affect defendant's substantial rights. 3. Although the district court did not abuse its discretion by denying defendant's proposed jury instructions, the district court abused its discretion by giving erroneous jury instructions on accomplice liability, and the error was not harmless because it cannot be said beyond a reasonable doubt that the error had no significant impact on the verdict. 4. The district court did not err by allowing the State to elicit testimony from defendant related to her proffer statements because defendant waived the evidentiary protections of Minnesota Rule of Evidence 410, and the statements were properly admitted as impeachment evidence. Reversed and remanded.