State of Minnesota v. Patrick William Benton

Minnesota case law summary by Attorney Richard Clem: criminal law.

State of Minnesota v. Patrick William Benton. MN criminal law

The defendant, Patrick William Benton, was convicted of first-degree murder in Anoka County. He admitted to police that he had been at the victim's apartment, but said that the victim had stabbed herself in a suicide, and that he had stabbed her only once, "to settle her down." The jury apparently didn't buy it, and he was convicted. He appealed to the Minnesota Supreme Court.

During the trial, the courtroom was closed to the public on two occasions. The defendant's attorney had requested this, since he didn't want some of the trial strategy to be discussed to possibly make its way to the jurors. The defendant agreed to these closures.

The Minnesota Supreme Court held that these closures did not violate the Sixth Amendment right to a public trial. They were requested by the defendant, and did not add any unfairness to the proceedings.

The high court also held that it was proper to admit relationship evidence under Minnesota Statute 634.20. The court held that any error was harmless.

No. A13-1605 (Minn. Jan 28 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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