State of Minnesota v. Jeremiah Quan Turner

Summary

The court affirmed Turner’s murder conviction, holding that his initial waiver of counsel was knowing, voluntary, and intelligent despite omissions in the district court’s advisories and that he validly renewed the waiver after the indictment increased the potential punishment. The court clarified that waiver validity presents a legal question reviewed de novo, while underlying factual findings receive clear-error review. It concluded that Turner’s consultation with counsel, written waiver, understanding of the risks, and reaffirmation after learning of the life sentence established valid waivers.