State v. Beganovic
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The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction of first-degree arson under Minn. Stat. 609.561, subd. 1, holding that the evidence provided at trial was sufficient to support Defendant's conviction.
On appeal, Defendant argued that the word "unlawfully" in the first-degree arson statute created an element of the offense that the State must prove beyond a reasonable doubt and that the State failed establish all of the elements of his crime by failing to present evidence to show that the burning of his house was "unlawful." The court of appeals affirmed the conviction. The Supreme Court affirmed, holding (1) under section 609.561, the State must prove that a person set a fire in a manner not authorized by law as an element of first-degree arson; and (2) the trial court failed properly to instruct the jury, but there was no reasonable likelihood that the jury would have reached a different result had it been properly instructed that the State was required to prove that Defendant started the fire unlawfully.
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