Murder Convictions Upheld in the Face of Claims of Multiple Legal Errors.

State v. Jenkins, Minn.S.Ct., 5/20/2010.  A jury convicted Mr. Jenkins of two counts of first degree premeditated murder and two counts of first degree felony murder; the trial court sentenced him to consecutive life sentences without possibility of parole on the first degree premeditated murder convictions.

The  investigation focused on Mr. Jenkins, whom the police knew had an outstanding bench warrant from another county.  Officers went to Mr. Jenkins’ rooming house; Mr. Jenkins came to the door and once officers figured out that he was Jenkins they arrested him.  According to the officers they allowed Mr. Jenkins to retrieve shoes and a coat from his room, during which an officer who went with Mr. Jenkins saw, among other things, two cell phones.  The officer conveyed that information to other officers who were preparing a search warrant.  After taking Mr. Jenkins out, other officers remained in the room to “freeze” the scene pending the search warrant; those officers happened to see the barrel of a handgun sticking out from under some clothing; this information also got sent along to the search warrant writers.  Jenkins denied returning to the room after greeting the officers and being arrested.

Mr. Jenkins complained that his arrest on the other county bench warrant was unlawful because it was a ruse to arrest him for the two homicides.  The appellate court quickly dismissed this argument, but to be safe it also said that there was probable cause to have arrested Mr. Jenkins on the homicides as well.  The appellate court also summarily rejected a claim that the police did not have authority to seize Mr. Jenkins’ clothes as part of the arrest. 

Mr. Jenkins challenged the search warrant by which police seized the cell phones and the gun.  The trial court had resolved a factual dispute in the state’s favor, that Mr. Jenkins had asked to reenter his room in order to get his shoes and coat.  There was no dispute that a female officer had entered the room to permit Mr. Jenkins’ guest to dress and leave.  That was enough for the appellate court to conclude that the officers were lawfully inside the room, where they then saw the cell phones and gun in plain sight.

Mr. Jenkins sought to introduce evidence that various alternative perpetrators had committed the homicides.  State v. Jones, 678 N.W.2d 1 (Minn. 2004) obligates a defendant to offer some evidence that has an inherent tendency to connect the alternative perp to the commission of the crime.  The appellate court concluded that Mr. Jenkins had not meet this threshold burden.  

Mr. Jenkins made a couple of other arguments, which the appellate court rejected.  You can follow the link at the top here to read about them.