3. Two Appeals In The Murder of Officer James Sackett in St. Paul

THE CRIME:  On May 22, 1970, activists in St. Paul were trying to draw the attention of the national Black Panthers movement.  Constance Trimble placed a fake 911 call which drew St. Paul Officer James Sackett to a house, where sniper Ronald Lindsey Reed waited with conspirator Larry Clark to murder Officer Clark.

Trimble was acquitted of murder.  She did not name her conspirators for 35 years.  Clark agreed to plead guilty and served five years for his role.  Reed was convicted and sentence without the possibility of release.

Chief Justice Lorie Skjerven Gildea rejected two appeals by Reed.

First, in 2007, the Supreme Court rejected Reed's 13 claims on his direct appeal.  See here.

     First, the Supreme Court the Supreme Court held that the district court had original jurisdiction over a defendant who was 19 years old when he committed an offense in 1970.

     Second, the Supreme Court held that the district court did not commit reversible error when it instructed the jury that a defendant indicted for aiding and abetting and conspiring with a named individual could be convicted upon proof that he aided and abetted or conspired with any individual.

     Third, the Supreme Court held that the evidence presented was sufficient to support the defendant’s convictions for first-degree murder and conspiracy to commit first-degree murder.

     Fourth, the Supreme Court held that the district court’s failure to give an accomplice corroboration instruction sua sponte was not plain error.

     Fifth, the Supreme Court held that the district court’s failure to give an instruction sua sponte limiting the use of evidence of other bad acts was not plain error.

     Sixth, the Supreme Court held that the district court did not err by replaying an audio tape of a 911 phone call at the request of the jury.

     Seventh, the Supreme Court held that of the seven remaining claims that Reed filed without the support of a lawyer, none constituted reversible error.

Second, in 2010, the Supreme Court rejected his first post-conviction appeal.  See here.

     First, the Supreme Court rejected Reed's claim that he was denied his constitutional right to self-representation is barred by Knaffla because appellant argued the same issue on direct appeal.

     Second, the Supreme Court rejected that his 2005 trial for a 1970 murder was time-barred by the statute of limitations. 

     Third, the Supreme Court rejected Reed's claim that he should not have been tried for both murder and abetting murder because he claimed that the 35-year delay for charging the abetting crime was time-barred by the statute of limitations.  The Supreme Court noted that there is no distinction between liability as a principal and liability for aiding and abetting for the purpose of calculating the limitations period under a statute of limitations.

     Fourth, the Supreme Court held that the post-conviction court did not commit reversible error when it denied appellant’s ineffective assistance of trial and appellate counsel claims.

     Fifth, the Supreme Court held that the post-conviction court did not commit reversible error when it denied appellant’s recanted-testimony claim.

              

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