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# Minnesota Court Orders New Trial Over Jury Instructions
- URL: https://www.theamericanquorum.com/state-news-minnesota-2026-09-23-b/
- Published: 2026-09-24T02:46:23.000Z
- Updated: 2026-09-24T02:46:23.000Z
- Description: Minnesota’s Supreme Court ordered a new trial for Michael LaFlex after finding that jury instructions improperly blocked consideration of heat-of-passion manslaughter, while upholding police seizure of his phone.
- Author: News Desk
- Tags: Policy, Minnesota

The Minnesota Supreme Court on Wednesday reversed Michael Lee LaFlex’s first-degree murder conviction and ordered a new trial, ruling that the trial judge’s instructions improperly prevented jurors from considering heat-of-passion manslaughter after they found him guilty of the greater offense. The [opinion](https://mncourts.gov/%5Fmedia/migration/appellate/supreme-court/standard-opinions/23sep26/OPA241417-092326.pdf?ref=theamericanquorum.com) leaves prosecutors free to retry the case; it is not an acquittal.

LaFlex was convicted of premeditated murder in the 2022 shooting death of Bryce Brogle in Crow Wing County and received a life sentence. The court’s [case summary](https://mncourts.gov/supremecourt/archivecalendars/2025-2026/march-2026?ref=theamericanquorum.com) says LaFlex sought to suppress evidence from his cellphone and asked jurors to consider first-degree heat-of-passion manslaughter as a lesser offense. His direct appeal and a postconviction challenge were consolidated before the Supreme Court.

The dispute centered on the sequence jurors were told to follow. According to the majority, the instructions directed the jury to stop after finding first-degree premeditated murder and therefore never reach the manslaughter count. The court concluded that this structure misstated Minnesota law and created a reasonable likelihood that the error had a significant effect on the verdict. Justice Paul Thissen wrote for the majority. Justices Anne McKeig, Karl Procaccini and Sarah Hennesy agreed with portions of the decision but disagreed with parts of the majority’s analysis or remedy.

Minnesota’s [lesser-offense law](https://www.revisor.mn.gov/statutes/cite/609.04?ref=theamericanquorum.com) allows a defendant to be convicted of the charged crime or an included offense, but not both. The state’s [murder statute](https://www.revisor.mn.gov/statutes/cite/609.185?ref=theamericanquorum.com) classifies an intentional, premeditated killing as first-degree murder and carries a life sentence. By contrast, the [manslaughter law](https://www.revisor.mn.gov/statutes/cite/609.20?ref=theamericanquorum.com) covers an intentional killing committed in the heat of passion provoked by words or acts that would cause an ordinary person to lose self-control. The Supreme Court’s ruling does not decide that the lesser offense applies; it says jurors must be allowed to evaluate it under legally correct instructions when the evidence supports the option.

LaFlex did not prevail on his separate challenge to the seizure of his phone. The court upheld officers’ decision to take the device without a warrant, finding probable cause and exigent circumstances because evidence could have been destroyed before a warrant was obtained. Officers later searched the phone under a warrant. That holding means the phone evidence is not excluded merely because of the initial warrantless seizure and can remain part of the prosecution’s case at a retrial, subject to other evidentiary rulings.

The practical effect is to return the prosecution to Crow Wing County for further proceedings. Prosecutors must decide how to proceed, and any new jury will receive instructions consistent with Wednesday’s ruling. The decision also gives Minnesota trial courts guidance on a recurring procedural point: jurors should not be told to bypass a supported lesser-included offense in a way that prevents them from fully considering the defense theory. The court’s public [opinion index](https://mncourts.gov/supremecourt/recentopinions/minnesota-supreme-court-opinion?ref=theamericanquorum.com) lists the decision as filed September 23, 2026.