State v. Anderson

789 N.W. 2d 227 (2010)

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State v. Anderson

Minnesota Supreme Court
789 N.W. 2d 227 (2010)

JC

Facts

Michael Anderson (defendant) was found guilty by a jury of first-degree premeditated murder, second-degree intentional murder, and second-degree manslaughter-culpable negligence for shooting Katherine Olson in 2007. Anderson was sentenced to life in prison without parole and appealed the conviction. In October 2007, police were called when Olson’s discarded purse was found in a park. After speaking with Olson’s roommate, police learned Olson had advised that the previous day, she was going to the town of Savage for a babysitting job. Olson had not returned. In reviewing Olson’s emails, police found emails from a sender named Amy regarding a babysitting job the previous day from 9 a.m. to 2 p.m. Olson’s final cell-phone call was 85 seconds at 8:57 a.m. to Anderson’s phone. Investigators subsequently found Olson’s vehicle, with Olson’s body in the trunk. Investigators reviewed computers at Anderson’s residence and found various postings online, including one seeking a babysitter for a 5-year-old girl. Anderson’s emails, sent as Amy, had arranged for Olson to come to Anderson’s residence at 9 a.m. on the date of Olson’s murder. Police also linked Anderson to the crimes with fingerprints, DNA, bullet comparisons, and Anderson’s statements. Anderson first pled not guilty by means of mental illness, claiming Asperger’s, a contention that the state (plaintiff) disputed. Anderson subsequently waived the mental-illness defense and, before trial, stipulated that Anderson was holding his father’s gun when the weapon fired, he caused Olson’s death, and he was acting alone. However, Anderson sought to introduce expert psychiatric testimony concerning the physical and cognitive effects Asperger’s had on him. The record provided no real indication of any impact of Asperger’s on Anderson in the hearing and proceedings of this case. The district court denied Anderson’s motion to admit the testimony. Anderson appealed the denial, arguing that the court abused its discretion and prevented Anderson from receiving a fair trial when the court denied his motion to present expert psychiatric testimony regarding Asperger’s and its effects.

Rule of Law

Issue

Holding and Reasoning (Dietzen, J.)

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