State of Minnesota v. Alberto Jimenez

Court of Appeals of Minnesota·Decided August 31, 2026·No. a260450·Unpublished

Opinion

This opinion is nonprecedential except as provided by Minn. R. Civ. App. P. 136.01, subd. 1(c).

STATE OF MINNESOTA

IN COURT OF APPEALS

A26-0450

State of Minnesota,

Respondent,

vs.

Alberto Jimenez,

Appellant.

Filed August 31, 2026

Reversed and remanded

Bond, Judge

Lyon County District Court File No. 42-CR-24-684

Keith Ellison, Attorney General, Jacob Campion, Assistant Attorney General, St. Paul, Minnesota (for respondent)

Paul Engh, Minneapolis, Minnesota; and Kent Marshall, Barrett, Minnesota (for appellant)

Considered and decided by Rasmusson, Presiding Judge; Johnson, Judge; and Bond, Judge.

NONPRECEDENTIAL OPINION

BOND, Judge This is an appeal from an order denying appellant’s ex parte application requesting funds for expert-witness services under Minn. Stat. § 611.21(a) (2024) to defend against criminal charges related to the death of his infant child. Appellant, who retained private

counsel at the outset of the prosecution but has since become indigent, argued in the district court that he is entitled to funds under the statute and, alternatively, that the statute is unconstitutional as applied because it violates his due-process right to present a defense. The district court determined that appellant was not entitled to funds under the statute’s unambiguous language and denied his motion without addressing appellant’s constitutional argument. We reverse and remand for the district court to consider whether section 611.21(a) is unconstitutional as applied to appellant.

FACTS

In June 2024, respondent State of Minnesota charged appellant Alberto Jimenez with second- and third-degree murder for the 2016 death of Jimenez’s infant child. See Minn. Stat. §§ 609.19, subd. 2(1), .195(a) (2014). The complaint alleged that, according to the opinions of medical providers, the child had been abused and died as a result of abusive head trauma (AHT).

Jimenez retained private counsel and moved for a Frye-Mack hearing to challenge the admissibility of the AHT diagnosis on the ground that it lacked foundational reliability. See Minn. R. Evid. 702 (requiring expert-witness opinions to have foundational reliability to be admissible). For support, Jimenez primarily relied on foreign legal authority calling into question the reliability of AHT diagnoses in infants. See State v. Nieves, 345 A.3d 1127, 1164-72 (N.J. 2025) (concluding that the government failed to establish that AHT was accepted in the relevant scientific community “because the research, studies, and testimony presented at the hearing reflect a lack of general acceptance in the biomechanical community regarding SBS/AHT without impact”). Jimenez also submitted expert opinions

disputing the state’s theory on the child’s cause of death and opining that the child’s subdural hematomas were not caused by trauma. The district court denied Jimenez’s request for a Frye-Mack hearing, but it ruled that Jimenez could move in limine to exclude or limit expert testimony on the AHT diagnosis based on foundational reliability.

In December 2025, in conjunction with other motions related to AHT and the child’s cause of death, Jimenez filed an ex parte application under Minn. Stat. § 611.21(a) and federal constitutional caselaw to authorize funds for expert-witness fees. Under the statute, appointed counsel representing an indigent defendant or counsel “representing a defendant who, at the outset of the prosecution, has an annual income not greater than 125 percent of the poverty line” as established by federal law may request expert or other services necessary to an adequate defense. Minn. Stat. § 611.21(a). Jimenez’s application alleged that (1) he suffers from a serious health condition and was indigent; (2) he had retained expert witnesses who would offer testimony at trial disputing the state’s theory on the child’s cause of death and, instead, opine that the child’s subdural hematoma and retinal hemorrhages were caused by pre-existing medical conditions; (3) he has a due-process right pursuant to Ake v. Oklahoma, 470 U.S. 68 (1985) and State v. Beecroft, 813 N.W.2d 814 (Minn. 2012), to present expert witnesses to counter the state’s experts; and (4) expert testimony is necessary to his defense but he is unable to compensate his expert witnesses “without statutory assistance.”

The district court denied the application in an order filed on January 8, 2026, determining that Jimenez was ineligible for funds because he is represented by private counsel and had not submitted financial information establishing that his annual income

was not greater than 125% of the poverty line at the outset of the prosecution in June 2024. See Minn. Stat. § 611.21(a). Jimenez subsequently filed a supplemental affidavit with financial and past employment information. On January 30, the district court again denied Jimenez’s motion for funds, finding that Jimenez’s income was greater than 125% of the poverty line at the outset of the prosecution and he is therefore financially ineligible for publicly funded expert services under the statute. The district court did not expressly analyze Jimenez’s due-process argument.

Jimenez moved for reconsideration, reiterating his argument that application of the financial eligibility criteria under section 611.21(a) violates his constitutional rights to due process and to present a defense. The district court denied Jimenez’s motion for reconsideration on March 4, 2026. 1 The district court acknowledged Jimenez’s “need” for expert services and found that Jimenez is “presently indigent, and his current income is not greater than 125 percent of the poverty line.” But it determined that, because section 611.21 “does not provide for any exceptions to the requirement that a defendant with private counsel have an annual income not greater than 125 percent of the poverty line at the outset of the prosecution,” it must deny Jimenez’s application. The district court did not address Jimenez’s constitutional argument.

Jimenez appeals.

1 The district court noted that Jimenez had not requested permission to file a motion for reconsideration as required by Minn. Gen. R. Prac. 115.11, but considered Jimenez’s motion as one requesting permission to file a motion for reconsideration and decided it on the merits.

DECISION

We review a district court’s decision to deny funds under Minn. Stat. § 611.21(a)

for an abuse of discretion, but we review issues of statutory interpretation de novo. State v. Cruz Montanez, 926 N.W.2d 434, 436 (Minn. App. 2019), rev. granted (Minn. Apr. 8, 2019) and appeal dismissed (Minn. Mar. 11, 2020).

Section 611.21(a) provides:

Counsel appointed by the court for an indigent defendant, or representing a defendant who, at the outset of the prosecution, has an annual income not greater than 125 percent of the poverty line . . . may file an ex parte application requesting investigative, expert, interpreter, or other services necessary to an adequate defense in the case.

Minn. Stat. § 611.21(a). “Section 611.21 ensures that the state provides indigent defendants with the raw materials integral to the building of an effective defense as required by the state and federal constitutions.” Cruz Montanez, 926 N.W.2d at 437 (quotation omitted).

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State of Minnesota v. Alberto Jimenez, (Mich. Ct. App. 2026).

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Related

Ake v. Oklahoma
470 U.S. 68 (Supreme Court, 1985)
United States v. Bagley
473 U.S. 667 (Supreme Court, 1985)
State v. Pederson
600 N.W.2d 451 (Supreme Court of Minnesota, 1999)
Janssen v. Best & Flanagan, LLP
704 N.W.2d 759 (Supreme Court of Minnesota, 2005)
State v. Tenerelli
598 N.W.2d 668 (Supreme Court of Minnesota, 1999)
Kucera v. Kucera
146 N.W.2d 181 (Supreme Court of Minnesota, 1966)
McCaughtry v. City of Red Wing
808 N.W.2d 331 (Supreme Court of Minnesota, 2011)
State v. Beecroft
813 N.W.2d 814 (Supreme Court of Minnesota, 2012)
State v. Krause
817 N.W.2d 136 (Supreme Court of Minnesota, 2012)
State v. Montanez
926 N.W.2d 434 (Court of Appeals of Minnesota, 2019)