Helen Ulvinen was convicted of first-degree murder for the killing of Carol Hoffman by Helen's son David Hoffman. David strangled and dismembered his wife Carol. He called his mother Helen to watch the children while he disposed of Carol's body. The Minnesota Supreme Court reversed Helen's conviction. There was no evidence that Helen influenced David's decision to kill his wife. As David's parent, Helen was insulated by statute from guilt as an accomplice after the fact for her conduct. The evidence at best showed that Helen passively acquiesced to David's plan, which is not a criminal offense under Minnesota law.

1. HaroldSowards
CJ 322, Tu/Th 9:30
9/27/15
State v. Ulvinen
313 N.W. 2d 425 (Minn. 1981)
1. Facts
 HelenUlvinenmovesintothe house onJuly26
 Carol Hoffmanletseveryone know she hatesher
 Carol refusessex fromherhusbandDavidHoffman,he chokesherandthendismembers
her
 CallsforhismotherHelentokeepwatchupstairsfor the children
 Daviddisposesof the bodyina bag and dropsit off inWeaverLake
 Davidphonesina missingperson reportandhimandhis mommake up a story
 Aug.19,1980 Davidconfessestothe murderof Carol and includesthatHelenknewall
aboutit
 Helengetsconvictedof 1st
degree murderpursuanttoMinn. Statute 609.05 subd.1
(1980) whichimposescriminal liabilityonone whointentionallyaids,advises,hires,
counsel orconspireswithorotherwise procuresanothertocommitacrime
 MinnesotaSupreme Courtreversedthisdecision
2. Issue
Is there evidence thatHeleninfluencedherson’sdecisiontokill hiswife?
3. Holdings
No,reversed
4. Reasoning
Insulatedbystatute (Minn.Stat.609.495 subd.21980) fromguiltas an accomplice after-the-fact
for suchconduct because of herrelationasa parent of the offender.The evidenceatbest
supportsthat Ulvinen passivelyacquiescedinherson’splantokill hiswife.The state hasn’t
provedbeyondareasonable doubtthatthe appellantwasguiltyof anythingbutpassive
approval.Minnesotastatutesdon’tmake anomissionof warningsomeone abouttheir
impendingdeathacriminal offense.If thatwasthe case more of the people thatDavidtold
aboutthe deathwouldbe heldaccountable,therefore the case mustbe reversed.