State v. Johnson

GARDEBRING, Justice

(dissenting).

I respectfully dissent because I disagree ■with the majority’s determination that the reverse Spreigl evidence is not relevant to Johnson’s ease. I would hold instead that the reverse Spreigl evidence is sufficiently similar to the offense in question that it should have been admitted.

A defendant has the right to show that crimes of a similar nature have been committed by some other person in order to cast doubt on the defendant’s identification as the person who committed the crime charged against the defendant. State v. Bock, 229 Minn. 449, 458, 39 N.W.2d 887, 892 (1949). As the majority has stated, the foundational requirements for a defendant seeking to introduce other crimes evidence is the same as that required to support the state’s introduction of “other crimes” evidence against the defendant. One of those foundational requirements is that the evidence be relevant and material to the ease, that is, the Spreigl incident must be similar to the charged offense either in time, location or modus oper-andi. See State v. Landin, 472 N.W.2d 854, 859 (Minn.1991).

The similarities between the reverse Spreigl incident the defendant here sought to introduce and the charged offense are striking. Both occurred on the streets of St. Paul in the late evening; both involved shooting at Asian individuals who were not known to the perpetrator; and both involved shooting five or six gunshots into a carload of Asian people with a .22 caliber gun while accompanied by a group of juveniles. Although the incidents were not particularly close in time, 16 months apart, they were not so far apart as to render the other similarities meaningless. The only difference between the charged offense and the prior offense was that the prior offense was a random act, while the charged offense was apparently a retaliatory act for a prior altercation. I do not believe this single difference provides a reasonable basis to exclude the reverse Spreigl evidence.

This court has allowed the state to introduce, against a defendant, “other crimes” evidence involving much less similarity to the charged crime than that presented here. In State v. Cogshell, 538 N.W.2d 120 (Minn.1995), a prosecution for selling crack cocaine, the court upheld the admission of a prior conviction of the defendant for selling crack because both the prior incident and the charged offense involved the selling of crack in the same general area of St. Paul, with the same method of packaging. Id. at 124. This was allowed despite the fact that such packaging is the standard method of packaging crack cocaine and that many sales of the drug occur in the same area every day. Id.

In State v. Lewis, 547 N.W.2d 360 (Minn.1996), a prosecution for first-degree felony murder in the course of a robbery, the court upheld the admission of prior convictions of the defendant for other robberies because both the charged offense and the prior offenses were all robberies or attempted robberies, were street crimes and were committed by a group, and all involved randomly-selected victims and the gratuitous infliction of injury or attempted infliction of injury and the use of a getaway car. Id. at 364. At the same time, however, the defendant’s involvement in the crimes was quite different: in the prior offenses he was merely the getaway driver, while in the charged offense he was the main perpetrator. Id. at 365 (Gardening, J., dissenting). Moreover, the offenses occurred in different cities, at different times of the day, more than three years apart, and involved entirely different types of weapons. Id. at 361, 365.

I have registered my disagreement with the outcome of both of these cases before, Cogshell, 538 N.W.2d at 124; Lewis, 547 N.W.2d at 365 (dissenting opinions of Gardening, J.), as well as with other cases where the similarities between the charged offense and the prior offenses by the defendant were equally weak. See State v. Walsh, 495 N.W.2d 602, 607 (Minn.1993); State v. Berry, 484 N.W.2d 14, 19 (Minn.1992) (dis*440senting opinions of Gardebring, J.). But given that these cases create the rule that binds the court today, we should at the very least apply that rule evenhandedly, treating defendants the same as we do the state when it comes to the introduction of other crimes evidence.

The majority relies on the discretion afforded to the trial courts in making eviden-tiary rulings, and appropriately so. But the rules for determining when- that discretion is abused should be the same for both sides in a criminal matter, the state and the defendant. We simply should not say the trial court is correct in allowing the introduction of marginally relevant evidence that supports the state’s case and excluding evidence, which is more relevant, when it supports the defense position.

I believe that the trial court in this instance erred, and the error was not harmless. I would therefore reverse.