A premeditated first-degree murder indictment will stand against an Oakdale woman who's already spent four years in prison for killing her newborn baby, but what happens next will be watched closely in Minnesota courtrooms.
Nicole Marie Beecroft was a 17-year-old high school senior when she was found guilty of first-degree murder and sentenced in 2008 to mandatory life in prison without parole for stabbing the girl as many as 135 times and throwing the infant into a trash can outside her house.
Now, whether Beecroft ever walks free depends on interpretations from a landmark U.S. Supreme Court ruling last summer that cast doubt on state laws that require life without parole for juvenile murderers. While not excluding mandatory sentences, the ruling said courts must consider mitigating factors of youth before imposing sentences.
"It's particularly a textbook example of what is wrong with mandatory sentences that don't allow any consideration of individual circumstance or culpability," said Barry Feld, a University of Minnesota law professor specializing in juvenile justice. "Because the Supreme Court said mandatory sentences violated the Constitution, half the states in the country are scrambling. We're in this bind now that she could be tried but she couldn't be sentenced under the only sentencing provision available if she was convicted of Murder 1."
Similar scenarios could play out elsewhere in Minnesota this year as at least a dozen murderers convicted when they were teenagers could argue that the high court's Miller vs. Alabama ruling struck down the state law under which they were sentenced. Feld predicts the Legislature this session will have to rewrite the mandatory sentencing law that sent Beecroft and others to prison, bringing it into line with the high court's conclusion.
In May, a closely divided Minnesota Supreme Court ordered a new trial for Beecroft on grounds that interference from the Dakota County attorney and a medical examiner not connected with the case undermined her defense.
Looking more mature
On Friday, Beecroft entered a Washington County courtroom looking more mature than the day in December 2008 when, wearing pigtails, she was sent to Shakopee prison for the rest of her life. Wearing eyeglasses and a dark green jail suit, Beecroft sat quietly beside her attorneys, public defenders Luke Stellpflug and Christine Funk.
In a motion hearing, they attempted to convince District Judge John Hoffman that he should dismiss the first-degree murder indictment altogether.
Funk argued that the U.S. Supreme Court ruling in effect negated the charge against Beecroft. The ruling determined that mandatory life sentences without parole for defendants younger than 18 violates the Eighth Amendment's prohibition on "cruel and unusual punishments," she said.
But prosecutor Karin McCarthy objected, saying an indictment doesn't constitute a punishment and because Beecroft's retrial has not begun nor has she been convicted or acquitted, it was premature for the court to consider the sentencing ramifications of Miller vs. Alabama.
"It's clearly an issue that has complications. I agree with all of you about that," Hoffman said before denying Funk's motion. He also denied her motion to return the case to the jurisdiction of juvenile court.
That means Beecroft's criminal trial will proceed this summer as scheduled, but Hoffman acknowledged that Beecroft's attorneys might want to appeal his order to a higher court. Should Beecroft be found guilty in a new trial, the judge said, the court could impanel a sentencing hearing as "a necessary remedy" to explore constitutional questions raised in Miller vs. Alabama about how children are different from adults when they commit crimes.
Neither Funk nor Stellpflug would comment after the hearing. Fred Fink, chief of the criminal division in the Washington County attorney's office, said they will pursue another first-degree premeditated murder conviction.
Beecroft, who's already served four years in prison and is now 23, is being held in the Washington County jail until her new trial in July. She was a senior at Tartan High School in Oakdale at the time of the birth and had hidden her pregnancy from others, even her mother, according to court documents.
"The Supreme Court clearly said, children are different," Feld said, referring to Miller vs. Alabama and two earlier rulings. "The court emphasized that the quality of their judgments even when they do horrible things cannot be equated with the culpability of adults. You look at this as a 17-year-old kid who was caught in a horrible situation who can't even tell her mother she's pregnant and doesn't see a way out of her situation. What she did is clearly wrong but it's exactly the kind of immature impulse decision that the Supreme Court cases are directed at."
Kevin Giles • 651-925-5037 Twitter: @stribgiles