State of Minnesota vs Wiggins
Annotate this Case
In this case, the appellant, Lyndon Akeem Wiggins, was convicted of first-degree premeditated murder, attempted first-degree premeditated murder, first-degree intentional murder while committing a felony (kidnapping), and kidnapping, all based on aiding-and-abetting theories of criminal liability. The crimes were related to the kidnapping and murder of realtor Monique Baugh, which involved Wiggins, his girlfriend Elsa Segura, and two other men, Cedric Berry and Berry Davis.
On appeal, Wiggins argued that the district court erred by denying his pretrial motion to suppress the cell-site location information (CSLI) for his cell phone as the facts alleged in the warrant application failed to establish probable cause. He also contended that the district court improperly instructed the jury by stating that it could find Wiggins guilty if Wiggins "or another (or others)" satisfied each element of the offense.
The Supreme Court of Minnesota held that the district court did not abuse its discretion in denying Wiggins' motion to suppress the CSLI. It found that the totality of the circumstances alleged in the search warrant application established a "fair probability" that evidence of a crime would be found in the CSLI records of Wiggins’s cell phone carrier.
However, the Supreme Court found that the district court erred in its instructions to the jury. The court determined that the instructions materially misstated the law as they allowed the jury to convict Wiggins of the charges based on the actions of others without reaching the issue of his liability under an aiding-and-abetting theory. The court concluded that this error was not harmless beyond a reasonable doubt. Consequently, the court reversed Wiggins's convictions and remanded the case for further proceedings consistent with its opinion.
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.