## Facts

- Courtney Bernard Clark was convicted in Ramsey County District Court for the murder of Rodney Foster and the attempted murder of Foster’s girlfriend, B.B., while committing or attempting aggravated robbery, kidnapping, and criminal sexual conduct.
- Foster invited Clark to stay at Foster’s apartment after learning Clark lacked stable housing; Clark observed drug activity at the apartment and used drugs with Foster and B.B.
- In the early morning hours of July 16, 2005, B.B. and Foster were in the living room when Clark and others arrived; the others soon left, and the events leading to Foster’s death and B.B.’s attempted killing occurred thereafter.
- The State introduced three recorded police interviews of Clark:
  - In the first two interviews, Clark denied involvement.
  - In the third interview, Clark admitted tying up Foster and B.B. and robbing Foster, asserted Foster’s death was “by accident,” and continued to deny sexual activity with B.B.
- At trial, Clark’s testimony was largely consistent with his third recorded interview and conflicted with B.B.’s testimony, the State’s primary account.
- Over defense objection, the district court admitted (1) all three recorded interviews and (2) evidence of Clark’s prior criminal sexual conduct conviction for substantive purposes.

## Issues

1. Whether the district court erred in admitting all three recorded police interviews, including interviews conducted after arraignment, in light of Clark’s challenges to admissibility.
2. Whether the district court erred in admitting Clark’s prior criminal sexual conduct conviction as substantive evidence.

## Decision

- The Minnesota Supreme Court affirmed Clark’s convictions.
- The court held the district court did not commit reversible error by admitting the three recorded interviews.
- The court held the district court did not commit reversible error by admitting Clark’s prior criminal sexual conduct conviction for substantive purposes.

## Legal Principles

- Recorded suspect interviews may be admitted when obtained and offered consistent with applicable constitutional protections (including the right to counsel and requirements governing custodial statements) and relevant evidentiary rules.
- Evidence showing changes in a defendant’s statements (from denial to partial admission) may be relevant to the jury’s evaluation of credibility when the defendant’s version conflicts with a key witness.
- A prior conviction may be admissible for substantive purposes if permitted by Minnesota evidence law; even if an evidentiary ruling is questionable, reversal requires a showing of prejudicial (non-harmless) error.

## Conclusion

The Minnesota Supreme Court affirmed Clark’s murder-related convictions, concluding that admission of his three recorded police interviews and his prior criminal sexual conduct conviction did not warrant reversal because the district court’s evidentiary rulings were not reversible error.


State v. Clark, 738 N.W.2d 316 (Minn. 2007)