Opinions
OPINIONS OF THE SUPREME COURT
RELEASED SEPTEMBER 30, 2026
NOTICE - MEDIA RELEASE TIME IS 10:00 A.M.
A25-0973 State of Minnesota, Respondent, vs. Johnny Leroy Brown, Appellant.
Hennepin County.
1. The district court did not clearly err in denying appellant’s Batson challenge to the State’s exercise of a peremptory strike against the only remaining Black venire member.
2. The district court did not abuse its discretion in admitting expert testimony about domestic violence.
3. The prosecutor’s statements during closing argument did not amount to prosecutorial misconduct.
4. The district court’s unobjected-to failure to instruct the jury that it had to unanimously agree on the domestic abuse element of the first-degree murder charge did not affect appellant’s substantial rights.
5. Any claims raised in appellant’s pro se supplemental brief are forfeited.
Affirmed. Chief Justice Natalie E. Hudson.
A25-0518 State of Minnesota, Respondent, vs. Tremaine Michael Bucholz, Appellant.
Hennepin County.
1. District courts should no longer apply the threshold-foundation first step for alternative-perpetrator evidence adopted in our decision in State v. Hawkins, 260 N.W.2d 150 (Minn. 1977), which required a defendant to provide evidence having an inherent tendency to connect an alleged alternative perpetrator with the commission of the crime before admitting evidence that a person other than the defendant committed the charged crime. Instead, district courts should apply the Minnesota Rules of Evidence in determining whether to admit alternative-perpetrator evidence.
2. The defendant is not entitled to a new trial where, despite the district court’s ruling excluding alternative-perpetrator evidence, the jury heard significant evidence of an alleged alternative perpetrator, had an opportunity to consider that party’s connection to the offenses charged, and there was strong evidence of the defendant’s guilt, thus rendering the district court’s ruling to exclude the evidence harmless beyond a reasonable doubt.
3. The entry of a conviction for second-degree murder in the sentencing order was clerical error and must be corrected.
Affirmed in part, reversed in part, and remanded to the district court. Justice Paul C. Thissen.
Concurring in part, dissenting in part, Chief Justice Natalie E. Hudson, Justice Anne K. McKeig, Justice Gordon L. Moore, III.
ORDER
A25-0901 In re Petition for Disciplinary Action against Carrie L. B. Klamecki Hendricks, a Minnesota Attorney, Registration No. 0397164.
Suspended. Justice Gordon L. Moore, III.