## Facts

- Katherine Olson went to Savage, Minnesota on October 25, 2007 for a babysitting job arranged through emails from “Amy” and did not return.
- Police found Olson’s purse discarded in a park trash can and later located her vehicle at a nearby park reserve; Olson’s body was discovered in the trunk.
- Electronic evidence linked the babysitting solicitation to Anderson, who used online postings and emails while posing as “Amy” to arrange the meeting at his residence.
- Forensic evidence connected Anderson to the crime, including DNA associated with a hair recovered from Olson’s body, additional DNA evidence on twine, fingerprints on a garbage bag connected to bloody items, and a thumbprint on Olson’s cell phone.
- Police took Anderson into custody at his airport job, transported him to the police station, advised him of Miranda rights, and he agreed to speak.
- During the interview, Anderson acknowledged making online postings, admitted being present when Olson was killed, and suggested involvement by a “friend”; questioning ended when he requested counsel.
- Anderson initially asserted a mental-illness defense and presented expert opinions diagnosing Asperger’s disorder, while court-appointed experts disagreed; he later withdrew the mental-illness defense.
- Before trial, Anderson stipulated that he held his father’s gun when it fired, he caused Olson’s death, and he acted alone.
- A jury convicted Anderson of first-degree premeditated murder (and lesser homicide offenses), and he received life imprisonment without possibility of release.

## Issues

1. Whether Anderson knowingly, intelligently, and voluntarily waived his Miranda rights.
2. Whether exclusion of expert psychiatric testimony about Asperger’s disorder, after withdrawal of a mental-illness defense, was an abuse of discretion or denied a fair trial.
3. Whether the trial court abused its discretion by refusing Anderson’s proposed jury instructions.
4. Whether the evidence was sufficient to prove premeditation for first-degree murder.

## Decision

- The Minnesota Supreme Court affirmed the conviction and life-without-release sentence.
- The court held the Miranda waiver was valid under the totality of the circumstances and Anderson’s statements were properly admitted.
- The court held the trial court acted within its discretion in excluding Asperger’s-related expert testimony as not relevant absent a mental-illness defense.
- The court held the jury instructions given fairly and adequately stated the law and refusal of proposed defense instructions was not an abuse of discretion.
- The court held the evidence, including the luring scheme and corroborating forensic proof, was sufficient to support a finding of premeditation.

## Legal Principles

- Validity of a Miranda waiver is evaluated under the totality of the circumstances and requires a knowing, intelligent, and voluntary waiver.
- Expert psychiatric evidence must be relevant to a material issue; excluding irrelevant mental-condition evidence is reviewed for abuse of discretion.
- Minnesota does not recognize an independent diminished-capacity doctrine permitting mental-impairment evidence to negate intent outside a formal mental-illness defense.
- Jury-instruction rulings are reviewed for abuse of discretion; instructions are sufficient if they fairly and adequately explain the applicable law.
- Sufficiency review considers the evidence in the light most favorable to the verdict; premeditation may be proved by circumstantial evidence, including planning activity and steps taken to lure a victim.

## Conclusion

The court upheld Anderson’s first-degree premeditated murder conviction, concluding that his custodial statements followed a valid Miranda waiver, the trial court properly excluded Asperger’s-related expert testimony after the mental-illness defense was withdrawn, the jury was correctly instructed, and the record contained sufficient evidence of premeditation.


State v. Anderson, 789 N.W.2d 227 (Minn. 2010)