State of Minnesota v. Gonzalo Galvan

Summary

The court affirmed Galvan’s convictions for two counts of first-degree premeditated murder. It held that the circumstantial evidence, including Galvan’s retrieval of the firearm, the motive evidence, and the manner of the shootings, was sufficient to establish premeditation. The court also held that Galvan was not prejudiced by the omission of a first-degree heat-of-passion manslaughter instruction because the jury found him guilty of premeditated murder, and clarified that premeditation and heat of passion are mutually exclusive mental states.