State v. St. Christopher

Brief Fact Summary. Defendant conspired with his cousin who was working with the police to kill Defendant’s mother. Defendant appeals a conviction for conspiracy and attempted murder.

Synopsis of Rule of Law. If the individual not feigning acquiescence has conspired within the meaning of the statute in the belief that the other party was with him, his culpability is not decreased by the other’s secret intention.

Facts. Defendant contacted his cousin to ask for help in his plan to kill his mother. The cousin testified for the prosecution and said that at no time did he plan to help Defendant. The cousin contacted the police who told him to continue to discuss the plan with the Defendant. On the day Defendant wanted his cousin to kill Defendant’s mother, the police arrested Defendant. Defendant was charged with conspiracy to commit murder, attempted murder. Defendant contends on appeal that he was the only willing party to the conspiracy and thus he could not be guilty of conspiracy as well as the attempted murder charge.

Issue. Whether the statute requires a meeting of the minds or in other words, two willing conspirators to support a conviction of conspiracy.

Held. Affirmed as the conviction for conspiracy and reversed as to the conviction of attempted first degree murder.
Minnesota will follow the unilateral approach to conspiracy in which there is no requirement that there be a meeting of the minds between the conspirators to support a conviction for conspiracy.

If the individual not feigning acquiescence has conspired within the meaning of the statute in the belief that the other party was with him, his culpability is not decreased by the other’s secret intention.

Discussion. The Court ruled that the plain language of Minnesota’s statute on conspiracy allowed the court to discard old precedent requiring a meeting of the minds for a conspiracy conviction to be supported. The Court noted that criticism had been advanced regarding this requirement because it would allow individual who had a culpable mental state to be acquitted because the other party to the conspiracy was not truly agreeing to commit the crime agreed upon.
Because Defendant was charged only with conspiracy to commit murder, the Trial Court could not find him guilty of attempted murder unless attempted murder is an included offense of conspiracy to commit murder, which it is not.