The deceased, Carol Hoffman was murdered by her husband on the or about the evening of 10th or the early morning of 11th August 1981. They had earlier on spent the day together with their children and everything seemed fine. However, when they went to bed at night, David wanted to make love to his wife and when she refused, he choked her to death. After his wife’s death, David went to the basement of the house to call his mother (appellant) and asked her to go and sit in the living room. Sitting in the living room enabled her to have a clear view of all the rooms in the house thus putting her in a position to intercept the children if any of them woke up and headed to the bathroom where her son was dismembering his wife. The appellant duly sat in the living room and after David was through, he disposed of the body in a nearby lake. Upon coming back he asked his mother to wash the cloth covers in the bathroom, a request which she duly complied with.
David came up with a story about his wife having left the house the previous night after an altercation and this is the story that both he and his mother told the police. About a week later, he confessed to having murdered his wife and that his mother knew of his intention to kill the deceased that night. It was also common knowledge that the appellant had a strained relationship with the deceased and had on numerous occasions expressed her desire to leave. The deceased had also made statements which were indicative of the strained relations between her and her mother in law. The jury in the trial court found that the defendant had violated the provisions of the Minnesota Statute 609. 5, subdivision 1 (1980) and accordingly convicted her of first degree murder.
The issues before the appellate court were whether the evidence adduced in the trial court was sufficient to establish a charge of first degree murder and the prejudicial effect of the statements made by the deceased regarding her relationship with her mother in law. The appellate court held that the evidence adduced by the prosecution did not establish that the appellant was guilty of first degree murder. It further held that that the probative value of the deceased’s statements was far outweighed by its prejudicial effect and thus ought not to have been admitted.
Among other things, the court noted that the deceased’s statements were inadmissible as they did not fall under any of the exceptions to the hearsay rule. Thus, the trial court had erred in allowing the jury to admit evidence which it ought to have excluded.
The court further stated that the evidence adduced by the prosecution at the trial did not meet the threshold set out to establish guilt in criminal cases which is beyond reasonable doubt. Put differently, the evidence adduced by the prosecution had certain loose ends whose effect was to create doubt the benefit of which favoured the accused. The appellate court observed that no evidence was adduced by the prosecution at the trial showing that that the defendant had formed an intention to kill the deceased.
In a dissenting opinion, Justice Yetka stated that he believed that the trial court had rightly admitted the deceased’s statements for the reasons it set out in the trial judgment. According to this dissention opinion, the import of these statements was that they showed that the defendant had reason to and was capable of having the requisite mens rea to murder or aid in murdering the deceased.
My considered view is that the appellate court made the right decision in allowing the appeal and setting aside the conviction of the accused person. It gave due regard to the fact that proof was not established beyond reasonable doubt. Where doubt exists, it would be an injustice to convict an accused person. The totality of the evidence adduced by the prosecution was such that it was insufficient to establish the guilt of the accused beyond reasonable doubt.