## Facts

- Charles Ray Barnes called 911 from his apartment near midnight, reporting he found his ex-wife, Erin Rooney, unconscious and not breathing and believed she overdosed on drugs or alcohol.
- Barnes told the dispatcher he dragged Rooney to the bathroom, tried to revive her with water, and performed chest compressions as instructed.
- Police and paramedics attempted resuscitation; Rooney was pronounced dead shortly after.
- An officer observed a syringe with liquid and a rolled-up dollar bill on a living-room table; Barnes said the syringe was Rooney’s and that she used heroin.
- Rooney had a puncture mark on her inner arm consistent with injection.
- Barnes gave varying accounts about the evening, including that they ate dinner, he went to bed, and later found Rooney unconscious.
- Officers initially treated the matter as a non-homicide death investigation and did not secure the apartment or collect physical evidence.
- An autopsy revealed multiple injuries, including defensive wounds, neck hemorrhaging, a broken hyoid bone, petechiae, facial swelling, and mouth injuries consistent with strangulation.
- The prosecution alleged Barnes strangled Rooney during a domestic assault and then injected heroin to stage an overdose; Barnes claimed overdose and disputed the cause of the injuries.

## Issues

1. Whether Minnesota’s first-degree domestic-abuse murder statute, Minn. Stat. § 609.185(a)(6), violates the Minnesota Constitution’s equal-protection guarantee due to alleged overlap with third-degree “depraved-mind” murder, Minn. Stat. § 609.195(a), but with a harsher penalty.
2. Whether the trial court abused its discretion and denied a fair trial by denying a continuance or mistrial after the defense expert became unavailable, and whether other asserted trial errors warranted reversal.

## Decision

- The Minnesota Supreme Court affirmed Barnes’s conviction and life sentence for first-degree domestic-abuse murder.
- The court held Minn. Stat. § 609.185(a)(6) constitutional and rejected the equal-protection challenge based on claimed statutory overlap.
- The court held the district court did not abuse its discretion in denying a continuance or mistrial to secure substitute expert testimony.
- The court rejected Barnes’s remaining claims of reversible error, including claims framed as ineffective assistance of counsel and prosecutorial misconduct, for lack of prejudicial impact on the verdict.

## Legal Principles

- A statute is not unconstitutional under equal protection merely because it overlaps with another criminal statute; overlap is permissible where the legislature targets distinct conduct or where each statute requires proof of an element the other does not.
- A specialized homicide statute may carry a greater penalty than a more general homicide statute when the legislature rationally identifies a distinct social harm and offender category (here, killing in the context of a patterned domestic-abuse relationship).
- Trial courts have broad discretion over continuances and mistrials; reversal requires a showing both of abuse of discretion and resulting prejudice affecting the fairness or outcome of the trial.
- Claims of prosecutorial misconduct or ineffective assistance warrant relief only upon a showing of prejudice material to the verdict.

## Conclusion

The court upheld Minnesota’s domestic-abuse murder statute as a valid, more specific homicide offense focused on patterned domestic abuse and affirmed the conviction, concluding that denial of a continuance or mistrial and other asserted trial errors did not amount to reversible prejudice.


State v. Barnes, 713 N.W.2d 325 (Minn. 2006)