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State v. Greenleaf4/15/1999
Constitution and Article I, section 7 of the Minnesota Constitution guarantee criminal defendants the right to present a meaningful defense. See U.S. Const. amends. VI, XIV; Minn. Const. art. I, § 7; Crane v. Kentucky, 476 U.S. 683, 687 (1986); State v. Richards, 495 N.W.2d 187, 191 (Minn. 1992).
A. Expert Testimony
The admissibility of expert testimony has generally rested in the discretion of the trial court and will not be reversed absent clear error. See State v. Koskela, 536 N.W.2d 625, 629 (Minn. 1995). Under Minn. R. Evid. 702, an expert witness may testify " f scientific, technical, or other specialized knowledge will assist the trier of fact to understand the evidence or to determine a fact in issue." Minn. R. Evid. 702.
Greenleaf sought to have two experts testify at trial, one regarding his claim that he was under duress during the commission of the crime, and the other regarding his claim that he was intoxicated during the commission of the crime. The testimony of both experts would only have been in regard to the general effects of alcohol and the general effects of duress. The trial court, citing Minn. R. Evid. 702 and our prior cases, did not allow the experts to testify, concluding that the jurors did not need expert testimony to understand either defense and therefore such testimony would not assist the jury "to understand the evidence or to determine a fact in issue." Id.; see also State v. Provost, 490 N.W.2d 93, 103 (Minn. 1992), cert. denied, 507 U.S. 919 (stating that "expert opinion testimony regarding the general effects * * * of intoxication is ordinarily inadmissible because most jurors have some experience with these conditions"); State v. Griese, 565 N.W.2d 419, 425 (Minn. 1997) (stating that because most jurors have some experience with mental illness and intoxication, expert psychiatric testimony as to the effects of those conditions is generally inadmissible).
The trial court also determined that the expert testimony would have invaded the jury's province by influencing its determination of whether Greenleaf was so intoxicated that he was unable to form the specific intent, or whether he was indeed acting under duress. See State v. Hoffman, 328 N.W.2d 709, 717 (Minn. 1982) (stating that only a jury can decide whether the defendant possessed the requisite capacity to commit the crime charged). The trial court did not commit clear error by determining that the proffered expert testimony invaded the exclusive province of the jury and, also, that the jury would not have been aided by this expert testimony.
B. Reverse Spriegl Evidence
Absent a clear abuse of discretion, evidentiary rulings generally rest within the trial court's discretion. See State v. Glaze, 452 N.W.2d 655, 660 (Minn. 1990). A defendant who claims the trial court erred in admitting evidence bears the burden of showing the error and any resulting prejudice. See State v. Steinbuch, 514 N.W.2d 793, 799 (Minn. 1994).
Pursuant to Minn. R. Evid. 404(b), a defendant may seek to introduce evidence of other crimes or misconduct of a third person to prove "motive, opportunity, intent, preparation, plan, knowledge, identity, or absence of mistake or accident." Minn. R. Evid. 404(b). In State v. Deans, we stated:
"If * * * the conduct of a third party * * * is an issue and if the evidence of "other crimes, wrongs, or acts" by the third party is not offered to prove the third party's character as a basis for an inference as to his conduct but instead is offered to prove the conduct of the third party without any need to infer his character, then the evidence is admissible." 356 N.W.2d 674, 676 (Minn. 1984).
Such evi
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