Court of Appeals grants 3rd trial for Watertown man charged in fatal St. Paul shooting
A Watertown man convicted of murder in a 2020 St. Paul shooting will get a new trial after he argued his constitutional rights were violated.
Monday, the Minnesota Court of Appeals ruled that Anthony Trifiletti’s Sixth Amendment Confrontation Clause rights were violated during his last trial when a key witness didn’t testify in person due to her possible exposure to COVID-19.
Trifiletti was involved in a minor traffic crash in St. Paul on May 1, 2020. After the vehicles pulled over onto Burns Avenue, Trifiletti and the driver of the other vehicle got into an argument that ended with Trifiletti shooting the other man, who died later that night.
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Trifiletti has claimed the shooting was in self-defense while prosecutors charged him with second-degree murder and manslaughter.
In March 2021, a jury failed to reach a unanimous verdict and a mistrial was declared. A month later, his second trial started and two witnesses reported being possibly exposed to COVID-19.
The appellate court says one of the witnesses had unidentified symptoms but was said to be getting better and her doctor advised her against taking a COVID test. A Ramsey County public health official told the court it was “reasonable” for the two to testify in person as long as they wore masks and followed social distancing requirements. However, the other witness’s doctor then recommended a 10-day quarantine.
On the third day of trial evidence, prosecutors argued that both witnesses couldn’t testify in person due to their possible COVID-19 exposures and pushed for them to either testify remotely or have their transcripts from the first trial read in court.
Trifiletti objected but the court deemed the witnesses’ possible exposure “a clear public health risk within the view of national and local guidance” and let Trifiletti choose whether to have the witnesses testify remotely or have their first trial transcripts read. Trifiletti again objected but the court decided that the options didn’t violate Trifiletti’s rights and added that it wasn’t inclined to delay the trial.
Trifiletti opted for the first trial transcripts to be read and jurors later convicted him of second-degree unintentional murder and manslaughter.
However, in a 2-1 decision, the Minnesota Court of Appeals determined that the state failed to prove any of the limited exceptions to allow the witnesses to not testify in person and, therefore, Trifiletti had his constitutional rights violated by not being able to confront the witnesses in court. Therefore, his request for a new trial was granted.
In the ruling, Judges Randall Slieter and Matthew Johnson said a witness’ possible COVID exposure by itself isn’t enough to render him or her unavailable. They added that even if the possible exposure presented a public health risk, the state failed to prove that an actual public health concern existed.
In her dissent, Judge Carol Hooten disagreed that a court may never find a witness who was exposed to COVID unavailable to testify in person, and said that because Trifiletti’s lawyer was able to cross-examine the witnesses at a prior trial and that transcript was read to the jury, his rights of confrontation weren’t actually violated. Finally, she argued that Trifiletti strategically chose to have the transcript read in court instead of having them testify remotely and also declined to file a continuance to delay the trial, so he can’t argue that he chose an unconstitutional method of presenting evidence.
The Ramsey County Attorney’s Office told 5 EYEWITNESS NEWS that it “will make a decision about next steps in the near future.”
5 EYEWITNESS NEWS also reached out to Trifiletti’s attorney for a statement on the ruling but hasn’t yet heard back.