## Facts

- Jon Earl Quick and Diane Quick separated in 2000; Diane obtained a restraining order limiting Jon’s access to the marital home and contact.
- Diane began dating Justin Mueller, who was frequently at Diane’s home.
- Quick sent Diane angry emails containing explicit threats directed at Mueller.
- On the night of the killing, Quick drove about 15 miles to Diane’s house with a loaded rifle, circled the block to avoid being seen, entered through a window, removed his shoes to reduce noise, went upstairs, and fatally shot Mueller in a bedroom.
- At trial, Quick testified he intended only to scare or humiliate Mueller but claimed he became suddenly enraged after hearing Diane giggling in a way he perceived as intimate.
- The jury was instructed on first-degree premeditated murder and first-degree heat-of-passion manslaughter as a lesser-included offense, and it convicted Quick of first-degree premeditated murder; the court imposed a life sentence.

## Issues

1. Whether the evidence was sufficient for the jury to find beyond a reasonable doubt that Quick did not act in the heat of passion upon adequate provocation, supporting first-degree premeditated murder rather than heat-of-passion manslaughter.
2. Whether excluding testimony from three defense witnesses violated Quick’s constitutional rights to present a defense and to a fair trial.
3. Whether Quick’s additional pro se claims (including judicial misconduct, instructional error, jury bias, evidentiary error, spousal testimony, ineffective assistance, and prosecutorial misconduct) required reversal.

## Decision

- The Minnesota Supreme Court affirmed the conviction and life sentence.
- The court held a rational jury could find beyond a reasonable doubt that Quick did not act in the heat of passion and that the evidence supported premeditation.
- The court held the exclusion of the three defense witnesses did not violate Quick’s constitutional rights and did not warrant a new trial.
- The court rejected Quick’s pro se claims as barred, unsupported by the record, or nonprejudicial.

## Legal Principles

- First-degree heat-of-passion manslaughter requires that the defendant acted in the heat of passion and was provoked by words or acts that would provoke an ordinary person to lose self-control under like circumstances.
- When a defendant introduces evidence supporting heat-of-passion manslaughter, the State must prove beyond a reasonable doubt that the defendant did not act in the heat of passion.
- Whether a killing was committed in the heat of passion or with premeditation is generally for the jury, which may consider the defendant’s conduct before the claimed provocation, including planning activity and prior threats.
- The constitutional right to present witnesses is subject to reasonable evidentiary limits; excluding cumulative or minimally probative testimony, or testimony properly excluded under evidentiary rules, is not reversible absent sufficient prejudice.

## Conclusion

The court upheld Quick’s first-degree premeditated murder conviction because the jury could reasonably infer deliberation from his prior threats and calculated, armed, and stealthy entry and approach, and because the challenged witness exclusions did not amount to a prejudicial denial of the right to present a defense.


State v. Quick, 659 N.W.2d 701 (Minn. 2003)