MN Criminal Law, Circumstantial Evidence

Minnesota case law summary by Attorney Richard Clem: MN Criminal Law, Circumstantial Evidence

State of Minnesota v. Dominic Jason Allen Sam. MN Criminal Law, Circumstantial Evidence

In this appeal from Pine County, the Minnesota Court of Appeals applied the rule that when the state's case is based largely, or entirely, on circumstantial evidence, there is sufficient evidence to sustain a conviction if and only if no other reasonable, rational inferences exist that are inconsistent with guilt. State v. AlNaseer, 788 N.W.2d 469 (Minn. 2010); State v. Silvernail, 831 N.W.2d 594 (Minn. 2013).

The Court of Appeals reversed the conviction. The gun and drugs had been found in the center console of the vehicle which defendant was driving, but the officer had seen the passenger moving toward that console. Even though the hypothesis of guilt might have been the most reasonable, there was still a reasonnable inference consistent with innocence.

The Court also held that the defendant in this case was not ineligible to possess a firearm.

No. A14-0096 (Minn. Ct. App. Feb. 17, 2015).

Please see the original opinion for the court's exact language.


Richard P. Clem is an attorney and continuing legal education (CLE) provider in Minnesota. He has been in private practice in the Twin Cities for 25 years. He has a J.D., cum laude, from Hamline University School of Law in St. Paul and a B.A. in History from the University of Minnesota. His reported cases include: Asociacion Nacional de Pescadores a Pequena Escala o Artesanales de Colombia v. Dow Quimica de Colombia, 988 F.2d 559, rehearing denied, 5 F.3d 530 (5th Cir. 1993), cert. denied, 510 U.S. 1041 (1994); LaMott v. Apple Valley Health Care Center, 465 N.W.2d 585 (Minn. Ct. App. 1991); Abo el Ela v. State, 468 N.W.2d 580 (Minn. Ct. App. 1991).

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