State Farm Mutual Automobile Insurance Company v. Havemeier

Background

State Farm moved before a scheduled bench trial for a ruling that Tyler Havemeier’s Alford plea to felony second-degree assault with a deadly weapon, along with the plea-hearing transcript, could be admitted as evidence. State Farm argued that the evidence was relevant to whether Havemeier intended to cause bodily injury to Jacob Gatzlaff and could also be used to challenge Havemeier’s testimony.

The court had previously rejected State Farm’s argument that Havemeier’s intent could be decided on summary judgment based only on the plea and the record underlying it. The court had not previously decided whether the plea could be admitted at trial.

Parties’ Positions

Gatzlaff stated that he did not object to admitting the plea materials because he had listed the complete plea transcript as one of his exhibits. He nevertheless disagreed with State Farm’s interpretation of the plea concerning Havemeier’s intent. The opinion also notes that Havemeier and Nikki Blank had not appeared in the case as of the order’s date.

Court’s Analysis

Federal Rule of Evidence 410 generally excludes certain withdrawn guilty pleas, pleas of no contest, statements made during proceedings on those pleas, and certain unsuccessful plea discussions. The court concluded that Havemeier’s Alford plea and plea-hearing transcript did not fall within those exclusions because the plea had not been withdrawn and the relevant statements were not from plea discussions that failed to result in a guilty plea or resulted in a later-withdrawn guilty plea.

The court also relied on the Minnesota Supreme Court’s distinction between a no-contest plea and an Alford plea. The court noted that Minnesota does not allow no-contest pleas and that Alford pleas are accepted after an inquiry into actual guilt, so they are treated as standard guilty pleas for purposes of Rule 410.

Disposition

The court granted State Farm’s Motion in Limine Regarding the Admissibility of Defendant Havemeier’s Alford Plea insofar as Tyler Havemeier’s Alford plea and plea-hearing transcript would be admissible at the upcoming bench trial. The order decided admissibility; it did not state that the plea alone established Havemeier’s intent.