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State v. Coleman
Minnesota Court of Appeals
944 N.W.2d 469 (2020)
Facts
Eric Joseph Coleman (defendant), intoxicated, drove his snowmobile at 58 miles per hour at night on a lake where people were ice fishing. A family of four had set up a portable six-foot-tall ice-fishing house, which had reflectors on all four corners. Coleman drove his snowmobile right at the family, striking and killing an eight-year-old boy, injuring the boy’s father, hitting the family’s pickup truck, and going straight through the fishing house. Coleman was charged with, and a jury found him guilty of, third-degree murder, two counts of criminal-vehicular homicide, two counts of gross-misdemeanor-criminal-vehicular operation, and two counts of gross misdemeanor driving while impaired (DWI). Coleman failed to object at trial to the use of model jury instruction for third-degree murder, which, as written, permitted conviction if Coleman acted with mere knowledge that someone may be killed. The district court sentenced Coleman concurrently to 150 months in prison for third-degree murder and 365 days in jail for one count of gross misdemeanor criminal vehicular operation. Coleman was not sentenced for the remaining offenses. Coleman appealed, arguing that the district court plainly erred in instructing the jury on the mens rea element of third-degree murder.
Rule of Law
Issue
Holding and Reasoning (Cochran, J.)
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