How to win an appeal of a conspiracy case: failure to prove the agreement factor of conspiracy

Appeals

Dec 25

Many people think that if you don’t physically commit the crime, you can’t be held criminally responsible. But that assumption could not be further from the truth. Minnesota has very expansive laws on charging conspiracy that allow prosecutors to charge conspiracy in a broad set of circumstances. You can be charged under the controlled substance conspiracy statute for conspiracy to commit any drug related crime. Minn. Stat. § 152.096. Or you can be charged for conspiracy to commit any other type of crime under Minn. Stat. § 609.175.

Legal Standard for Conspiracy Crimes

The government needs to demonstrate two elements to prove a conspiracy: (1) a person entered into an agreement with another to commit a crime; and (2) there was an overt act in furtherance of the conspiracy. See State v. Hatfield. A cursory reading may make you think the government need testimony about the “agreement”. But the problem is that Minnesota has lowered the hurdle the government needs to overcome in proving this saying, "'Conspiracy need not be established by direct evidence, but may be inferred from the circumstances.” If you were convicted based on only circumstantial evidence, there are ways to challenge the conviction. This blog post will look at one such case.

State v. Hatfield and Insufficient Evidence of a Conspiracy

In State v. Hatfield, 627 N.W.2d 715 (Minn. Ct. App. 2001), Defendant got the help of a friend to help transport a cooler and propane tank to Defendant’s residence. aff'd on other grounds, 639 N.W.2d 372 (Minn. 2002). The jury convicted the defendant of conspiracy to sell meth among other charges in Martin County, Minnesota. The defendant appealed, and the Court of Appeals reversed the conspiracy conviction because of insufficient evidence. The Court of Appeals looked at there not being evidence that the defendant’s friend knew that it was defendant’s intent to use the propane tank to manufacture meth and that there was no evidence of there even being a discussion. The Court of Appeals said, “an innocent courier cannot be considered a co-conspirator.” This was a case where the evidence was so bare bones, that the alleged circumstantial evidence was not enough to convict of conspiracy. The Court of Appeals reversed the conspiracy conviction and the Supreme Court affirmed on other grounds.

Conclusion

If you or a loved one were convicted of conspiracy, you should contact a skilled Minnesota appeals attorney. Jack Rice Defense utilizes its extensive knowledge of criminal defense and appeals to craft the best strategy to counteract the conviction in your case. It’s important for you to act fast because generally the deadline to appeal felony and gross misdemeanor cases is 90 days; and 30 days for misdemeanors. Contact Jack Rice Defense if you want to appeal your case. (651) 447-7650