MN Appeals Court Reverses Proctor Murder Conviction

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

State of Minnesota v. Paul Joseph Welle. MN criminal law

Paul Joseph Welle was convicted of murder in St. Louis County, Minnesota, District Court after punching a man outside a bar in Proctor, Minnesota. He claimed self defense, but the prosecution was allowed to show evidence of three prior assaults in 2001, 2002, and 2003. He appealed to the Minnesota Court of Appeals and argued that the lower court had erred in allowing the evidence of the prior assaults.

In order for such evidence to be admissible, it must have a relevant purpose. The Court of Appeals agreed, and held that the state had not shown that the evidence disproved the self-defense claim. For that reason, it remanded the case for a new trial.

No. A13-0256 (Minn. Ct. App. May 27, 2014).

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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