How did the Minnesota Supreme Court interpret the third‑degree murder statute in Noor’s appeal?
Executive summary
The Minnesota Supreme Court unanimously narrowed the state’s third‑degree “depraved‑mind” murder statute in State v. Noor, holding that the mental‑state element requires a generalized indifference to human life and therefore cannot be satisfied when a defendant’s lethal conduct is directed with particularity at a single person; as a result the court reversed Noor’s third‑degree murder conviction while leaving his second‑degree manslaughter conviction intact [1] [2]. The decision framed third‑degree murder as reserved for indiscriminate, eminently dangerous acts that threaten “others” in general, not individualized shootings [3] [4].
1. The statute’s mental state: generalized indifference, not individualized targeting
The court read Minn. Stat. § 609.195(a) to require proof that the defendant acted with a “depraved mind” — a generalized indifference to human life — and explained that such a mental state cannot exist when the conduct is directed “with particularity” at the person who died; applying that standard to the record, the court concluded Noor’s single shot was particularized and therefore insufficient to sustain a depraved‑mind conviction [1] [2]. Multiple legal observers and defense briefs had urged this interpretation, pointing to longstanding Minnesota precedent that treats the statute as aimed at broadly dangerous conduct like shooting into crowds or drug‑distribution overdose schemes, rather than one‑on‑one killings [5] [3] [4].
2. The unanimous reversal and its immediate effect on Noor’s sentence
Because the court found insufficient evidence of the statutory depraved‑mind element, it vacated Noor’s third‑degree murder conviction; the court left in place his conviction for second‑degree manslaughter, meaning Noor would be resentenced on the lesser count and the murder sentence was undone [2] [6]. Coverage from local outlets summarized the result bluntly: the third‑degree count “doesn’t fit the circumstances” of Noor’s shooting, and the case returns to district court for resentencing on manslaughter [2].
3. The prosecution’s counter‑argument and broader prosecutorial concerns
Prosecutors warned the court that accepting Noor’s reading would eviscerate the utility of the third‑degree statute for many officer‑involved killings, because nearly all police shootings are targeted at a particular person; they argued reversal could hamper prosecutions in other high‑profile cases and urged the court to preserve the conviction to maintain a tool for police accountability [5] [7]. At oral argument at least one justice explicitly raised whether an interpretation for Noor would make third‑degree murder unavailable in officer‑involved shootings, underscoring the practical stakes flagged by prosecutors [5] [8].
4. The court’s balancing: narrow the element but keep third‑degree available in some cases
The Supreme Court rejected the prosecution’s slippery‑slope framing by clarifying that third‑degree murder still applies when a defendant’s conduct manifests a true generalized indifference to human life — for example, conduct that is eminently dangerous toward others generally, such as firing indiscriminately into a crowd — but that element is not met when the threat is particularized at the eventual victim [1] [2]. That framing preserves the statute for indiscriminate, dangerously reckless behavior while excising its use where the evidence points to targeting of a single person [3] [4].
5. The ripple effects and contested readings in commentary
Legal commentators immediately flagged potential ripple effects: the decision directly affects Noor and could be asserted as precedent in appeals by other defendants convicted under the depraved‑mind theory, including officers in the George Floyd prosecution, though practical sentencing outcomes may remain unchanged unless other convictions are overturned [7] [8]. Some practice‑oriented writeups reflected confusion in the aftermath — claiming the statute might still be applied even where only one person was endangered under certain textual canons [6] — but the Supreme Court’s controlling, unanimous ruling itself squarely stated the depraved‑mind element cannot be satisfied when conduct is shown to have been directed with particularity at the decedent [1] [2].
6. What the ruling means for charging and proof going forward
Prosecutors who wish to pursue depraved‑mind murder now must develop evidence that an accused’s conduct manifested a broad, generalized disregard for human life independent of a particular victim; defense attorneys will press for acquittal of third‑degree counts in cases where the state’s proof shows targeted conduct. That doctrinal clarification shifts the charging calculus in police‑use‑of‑force cases and ordinary homicides alike, forcing clearer differentiation between intentional killings, manslaughter, and truly indiscriminate depraved‑mind murder [3] [4].