Precedents Cited and Their Influence

• Taylor v. Louisiana (U.S. 1975): Establishes the constitutional right to a jury pool drawn from a fair cross-section of the community. This foundational principle frames the Sixth Amendment issue throughout.
• Duren v. Missouri (U.S. 1979): Provides the federal three-prong test for fair-cross-section claims—distinctive group, unfair representation, and systematic exclusion—that Minnesota has adopted and adapted.
• State v. Williams (Minn. 1994): Minnesota’s canonical articulation of the Duren test for state practice. The Court again applies Williams’s three prongs to the panel drawn from the jury pool.
• Berghuis v. Smith (U.S. 2010): Warns that pointing to a list of possible contributors to underrepresentation is not enough; a defendant must show systematic exclusion by state selection procedures as opposed to external factors (e.g., nonresponse).
• Andersen v. State (Minn. 2020): Held that a record without historical or statistical proof will not establish systematic exclusion. Crucially, Weeks clarifies Andersen is not a categorical endorsement of voter/driver source lists against all challenges; absent proof, Andersen held no violation—but where expert evidence exists, a hearing is appropriate.
• State v. Smith (Minn. 2024): Emphasized the need to measure representation against the jury-eligible population and to rule out alternative explanations for any underrepresentation. Weeks signals potential recalibration of Smith if petitioners cannot reasonably access data needed to satisfy those demands.
• State v. Roan (Minn. 1995) and State v. Griffin (Minn. App. 2014): Cited by the district court for the proposition that voter/driver source lists typically do not systematically exclude people of color. Weeks cautions that this line is not dispositive where a petitioner presents a supported record and modern data realities.
• Hennepin County v. Perry (Minn. 1997): Reinforces the Sixth Amendment fair cross-section principle under Minnesota law.
• Postconviction standards: Munt v. State (Minn. 2023); Crow v. State (Minn. 2019); State v. King (Minn. 2023); State v. Sardina-Padilla (Minn. 2024); Thoresen v. State (Minn. 2021); Ezeka v. State (Minn. 2025). Collectively, these cases instruct that summary denial is improper unless the petition and record conclusively show no entitlement to relief, and that doubts about holding a hearing are resolved in favor of petitioners.
• State v. Balandin (Minn. 2020) and Minn. Stat. § 609.04: Establish and apply the “one conviction” rule for included offenses. Every lesser degree of murder is an included offense; multiple homicide convictions based on the same act and victim cannot stand.

Legal Reasoning

The Court’s reasoning operates on two tracks: the fair-cross-section claim and the included-offense bar.

1) Fair-Cross-Section Claim and the Postconviction Hearing Standard

The governing postconviction standard is straightforward: a district court must hold an evidentiary hearing unless the petition and the record conclusively show that the petitioner is entitled to no relief. Allegations are viewed in the light most favorable to the petitioner, and doubts about the need for a hearing are resolved in the petitioner’s favor. A court may summarily deny a petition only when the alleged facts—even if true—are legally insufficient.

Applying that standard, the Supreme Court identified several reasons why denial was an abuse of discretion:

• The district court misapplied Andersen. Andersen is not a blanket approval of voter/driver source lists against all systematic-exclusion claims. It merely rejected a claim unsupported by historical or statistical evidence. Weeks, by contrast, offered an expert affidavit and statistical analysis, as well as a showing that race data is difficult to obtain, in part due to privacy laws and data practices.
• The district court failed to view the facts in the light most favorable to Weeks. The expert evidence asserted that contemporary use of voter registration and driver’s license lists may no longer produce racially representative jury pools, and it posited plausible mechanisms for underrepresentation. The court did not grapple with these allegations and their implications for the “systematic exclusion” prong.
• The petition raised material fact questions on prongs two and three of Williams that cannot be resolved without a hearing. These include whether the source lists remain fair and equitable, whether it is reasonably possible to compute jury-eligible Black populations with available data, and whether any underrepresentation can be shown to be the product of state procedures rather than alternative explanations like nonresponse or hardship excusals.

The Court also noted practical and procedural points that sharpen these fact disputes:

• Minnesota’s Jury Management Rules (Rule 806) require use of voter registration and driver’s license/ID lists to generate the jury source list. Statewide software (JSI’s “WebGen”) merges the lists and removes decedents. In 2024, authority to supplement the lists shifted from county officials to the statewide Judicial Council.
• County officials typically do not collect race information for juror administration, and agencies that supply source lists (Secretary of State for voter registration and DPS Driver and Vehicle Services for driver’s licenses/IDs) do not collect race data. This complicates empirical proof.
• However, Minnesota General Rule of Practice 814 authorizes courts, “in the interest of justice,” to order disclosure of summons-related information that can be generated from the jury system, notwithstanding privacy protections for certain categories (e.g., hardship details). This may enable case-specific data gathering necessary to test claims.

On the second prong (fair representation in the venire), the Court flagged that Professor Schultz’s adjustments to census data (e.g., excluding 18–19-year-olds due to grouping issues) raise a factual question about whether the record provides “accurate data about the racial demographics of the jury-eligible population” as Smith requires. Whether such calculations are reasonably possible with independent studies or available government sources is a material fact question.

On the third prong (systematic exclusion), the Court emphasized that a defendant must connect underrepresentation to “unfair or inadequate selection procedures used by the state,” as opposed to external causes like nonresponse or hardship excusals. Smith underscores this requirement. But Weeks introduces an important nuance: if it is not reasonably possible for a defendant to obtain data to rule out those alternative explanations, the Court may need to revisit the breadth of Smith’s evidentiary demands. That is a significant—if conditional—signal of doctrinal flexibility responsive to data-access realities.

Finally, the Court confirmed that, if a prima facie case is established on remand, the State may rebut it by showing the system “manifestly and primarily advances a significant state interest that is incompatible with the fair cross-section requirement” (the Duren/Williams rebuttal).

2) Included-Offense Bar Under § 609.04

The Court’s analysis on the multiple convictions issue is concise and grounded in settled law. Minnesota Statutes § 609.04 forbids entering convictions for both a charged offense and any included offense arising from the same act. Balandin confirms that all lesser degrees of murder are included offenses. Because Weeks was convicted of first-degree premeditated murder for the same act and victim, the district court erred by also entering convictions for first-degree domestic abuse murder and second-degree intentional murder. Those convictions must be vacated on remand.

Impact and Forward-Looking Implications

1) Procedural Protections for Fair-Cross-Section Challenges

Weeks establishes that expert-supported fair-cross-section challenges cannot be brushed aside with categorical references to voter/driver source lists. Instead, district courts must hold evidentiary hearings where the petitioner’s allegations raise genuine disputes about the fairness of source lists, the feasibility of obtaining eligibility-based demographic denominators, and whether underrepresentation is attributable to state selection procedures rather than alternative explanations.

This framework likely increases the frequency and rigor of evidentiary hearings on jury composition in Minnesota, especially in counties with demographic changes or persistent concerns about nonresponse and hardship excusals. It also encourages the development of a fuller empirical record, including potential court-ordered disclosures under Rule 814 and collaboration with jury administrators and data-holding agencies.

2) Substantive Doctrinal Trajectory: Potential Recalibration of Smith

Weeks signals that the Court is attentive to the practical difficulties defendants face in proving complex causation chains without race-linked juror data. If petitioners credibly demonstrate that it is not reasonably possible to obtain the data needed to tie underrepresentation to state procedures and to rule out alternative explanations, the Court may revisit aspects of Smith’s demands. That could shift some evidentiary burdens, modify the rigidity of current proof structures, or spur policy-level responses for race-data collection and analysis consistent with privacy protections.

3) Jury Administration and Policy

The opinion invites renewed scrutiny of how Minnesota constructs and manages its jury source list:

• The move of supplementation authority to the statewide Judicial Council (Rule 806) may prompt consideration of additional source lists to improve representativeness if credible evidence shows persistent underrepresentation.
• Courts may more frequently use Rule 814 to obtain data necessary for specific litigation, balancing privacy with the “interest of justice.”
• Jury offices may revisit outreach, follow-up on nonresponses, and hardship policies, given that these factors can drive disparities and thus become central in litigation.

4) Continued Enforcement of the Included-Offense Rule

The § 609.04 ruling reinforces a bright-line practice point: when a defendant is convicted of first-degree premeditated murder, all lesser-included homicide convictions based on the same act and victim must be vacated. District courts must enter only one conviction and sentence accordingly. This avoids collateral consequences of multiple convictions and simplifies postconviction clean-up.