What happened
The Eighth Circuit on Thursday affirmed the denial of habeas relief for Jquan Leearthur McInnis, rejecting his bid to undo a Minnesota murder conviction tied to the shooting death of an infant after state courts found that an improperly admitted confession did not change the outcome.
McInnis argued that the Minnesota Supreme Court unreasonably applied clearly established federal law when it held that the trial court's consideration of his confession, obtained after he invoked his right to remain silent, was harmless beyond a reasonable doubt. The federal appeals court said he had not met the demanding standard for relief under the Antiterrorism and Effective Death Penalty Act.
McInnis was convicted after a bench trial on stipulated evidence of two counts of first-degree murder and sentenced to two consecutive life terms with the possibility of parole. The underlying case stemmed from a 2016 downtown Minneapolis shooting in which McInnis fired multiple shots at Gustav Christianson and a final shot through a car's rear window that killed an infant identified as J.R.
The Minnesota Supreme Court had agreed that McInnis' confession should have been suppressed, but it concluded the error was harmless because other admissible evidence supported the intent finding. McInnis later sought federal habeas relief, and the district court denied the petition while allowing him to appeal the harmless-error issue.
Writing for the Eighth Circuit, Judge Gruender said McInnis had to show not only grave doubt about whether the confession affected the verdict, but also that the Minnesota Supreme Court's harmless-error decision was beyond the range of fairminded disagreement under AEDPA. The panel found he could not make that showing.
The court emphasized that a fairminded jurist could credit the timing and trajectory evidence surrounding the final shot and conclude the state proved the required intent. It also rejected the argument that admission of the confession was harmful per se, noting that McInnis denied in the confession that he intended to kill Christianson.
The decision leaves in place the district court's denial of McInnis' habeas petition and his Minnesota conviction for J.R.'s murder.