BRAINERD — A new trial has been granted for a rural Brainerd man serving a life sentence without parole after killing his daughter’s boyfriend in 2022.
The Minnesota Supreme Court reversed the conviction of Michael L. LaFlex and remanded his case back for a new trial in an opinion released Wednesday, Sept. 23.
LaFlex was convicted of first-degree premeditated murder by a Crow Wing County jury in 2024. He shot and killed Bryce Brogle at a Merrifield storage facility in October 2022. He buried Brogle’s body in a shallow grave in the woods nearby and dumped Brogle's cellphone in a trash can in Brainerd.
LaFlex told police he believed Brogle was abusing his daughter and intended to confront him about the abuse when the two were alone. He said the confrontation became heated.
A majority of Supreme Court justices agreed that the district court made a plain error in how it instructed the jury.
Among the three charges LaFlex faced in the case was first-degree heat-of-passion manslaughter. The judge told the jurors that if they determined LaFlex was guilty of premediated murder, it should disregard this lesser offense.
In the analysis, Justice Paul Thissen opined there was evidence in the record to support a rational jury finding that LaFlex acted in the heat of passion. But the state’s highest court ruled the district judge made an error when they told jurors to consider charges in a particular order. This is because it could cause the jury to evaluate the evidence differently.
The opinion stated the jury instruction affected LaFlex’s “substantial rights and must be corrected to ensure the fairness and integrity of the judicial proceedings.”
The Supreme Court denied another part of LaFlex's appeal, in which he argued evidence collected from his cellphone should be suppressed because law enforcement did not have a warrant when it was seized.
The court determined the seizure of the phone by the Crow Wing County Sheriff's Office was reasonable while it obtained a warrant, because LaFlex was not in custody and there was a risk he would destroy evidence. LaFlex had already attempted to destroy evidence by throwing away Brogle's phone.
Three justices concurred with the conclusion regarding the cellphone, but dissented in granting LaFlex a new trial based on the jury instructions: Justices Anne McKeig, Gordon Moore III and Sarah Hennesy.
In the dissent, McKeig wrote that LaFlex's defense invited the error by "affirmatively consenting to the district court's jury instruction on the order in which the jury should consider the charges." There was evidence supporting premeditation as well, the opinion stated, and LaFlex did not dispute any of that evidence when presenting his theory of defense for the jury to consider.
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