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Law School Case Brief

State v. Wahlberg - 296 N.W.2d 408 (Minn. 1980)


A conviction may stand only where the facts and circumstances disclosed by the circumstantial evidence form a complete chain which, in the light of the evidence as a whole, leads so directly to the guilt of the accused as to exclude, beyond a reasonable doubt, any reasonable inference other than that of guilt. An appellate court's scope of review on appeal is limited to considering the evidence and determining whether the jury could reasonably find the accused guilty. The court must view the evidence in the light most favorable to the State and must assume that the jury believed the State's witnesses and disbelieved everything which contradicted their testimony. 


Defendant Roy Eric Wahlberg was convicted, after a jury trial, in St. Louis County District Court of the first-degree murder of Jeffrey Goedderz and was sentenced to life imprisonment. On appeal, he challenged the sufficiency of the evidence, the refusal of the trial court to submit the lesser included offense of murder in the third degree, the trial court's instruction on voluntary intoxication, the requirement that he present evidence of voluntary intoxication that negates the existence of a necessary mental state, improper comments of the prosecutor, the admission of impeachment evidence without a limiting instruction, and the refusal of the trial court to grant a mistrial due to mid-trial newspaper publicity. 


Was Wahlberg’s conviction proper?




The court affirmed Wahlberg's conviction because (1) substantial circumstantial evidence supported the jury's verdict beyond a reasonable doubt, (2) the circumstances justified the jury finding premeditation existed as defined by Minn. Stat. § 609.18 (1978) notwithstanding Wahlberg's intoxication, (3) the prosecution's comments during closing arguments were harmless error or legitimate arguments on the evidence, (4) the trial court did not err by refusing to instruct the jury on the lesser-included offense of third-degree murder, and (5) a newspaper story about the case did not taint the jury where there was no evidence that jurors read the story or that jurors were prejudiced by the story.

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