State of Minnesota, Respondent,

This opinion is nonprecedential except as provided by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
A25-0097

State of Minnesota,
Respondent,

vs.

Quenton Tyrone Williams,
Appellant.

Filed January 12, 2026
Affirmed
Jesson, Judge*

Ramsey County District Court
File No. 62-CR-22-3816

Keith Ellison, Attorney General, St. Paul, Minnesota; and

Irene Kao, St. Paul City Attorney, Jack Billion, Assistant City Attorney, St. Paul,
Minnesota (for respondent)

Cathryn Middlebrook, Chief Appellate Public Defender, Michael McLaughlin, Assistant
Public Defender, St. Paul, Minnesota (for appellant)

Considered and decided by Worke, Presiding Judge; Cochran , Judge; and Jesson,
Judge.

* Retired judge of the Minnesota Court of Appeals, serving by appointment pursuant to
Minn. Const. art. VI, § 10.
2
NONPRECEDENTIAL OPINION
JESSON, Judge
Appellant Quenton Tyrone Williams challenges his misdemeanor convictions of
giving a false name to a peace officer, fleeing a peace officer, and fifth-degree assault,
raising issues that highlight the tension between the constitutional rights to a speedy trial
and to not be tried while incompetent, as well as the rights to counsel and self-
representation. He argues that (1) the 29-month delay in bringing the charges to trial
violated his right to a speedy trial, (2) the district court failed to follow applicable
procedures during the year-long process that led to him being found competent to proceed
to trial, and (3) the district court abused its discretion by refusing to reappoint counsel and
trying him in absentia. In a pro se supplemental brief, he advances additional arguments
regarding judicial bias, jury instructions, and exclusion of a witness. Because Williams
has not substantiated any of the errors he asserts, we affirm.
FACTS
On July 8, 2022, following an incident at a grocery store, appellant Quenton Tyrone
Williams was charged by citation with three misdemeanors: giving a false name to a peace
officer, fleeing a peace officer, and fifth-degree assault. Following arraignment in October
and a pretrial hearing in November, trial was set for March 2023. It was later rescheduled
to May because of a pending examination to determine whether Williams was competent
to stand trial on unrelated Dakota County charges, meaning that he had the ability to consult
rationally with counsel and understood the proceedings against him. See Bonga v. State,
797 N.W.2d 712, 718 (Minn. 2011).
3
The Dakota County examination report was submitted at the end of May. It noted
that Williams refused to participate in a structured examination for competence but opined,
based on an interview with him and collateral information, that he was competent. The
Ramsey County District Court here ordered the Dakota County report filed into this matter
on June 13 and set a hearing for the following day.
Competency Proceedings
At the June 14 hearing, defense counsel voiced concerns about the Dakota County
report and asked the district court to order a new competency examination in this matter.
The court denied the request, saying it would “treat the evaluation completed in that other
county as our first evaluation” and noting that the defense could object to it. Defense
counsel said she would obtain an independent examination and thereafter filed a written
objection to the Dakota County competency report.
At review hearings in July and October, defense counsel reported that she had not
yet obtained an independent examination but declined to provide further explanation, citing
attorney-client privilege. In the meantime, another Ramsey County judge ordered a
competency examination in a new case. The judge in this case vacated the order, over
defense objection, because “we’re in the middle of determinations of competency.” A
hearing in this matter —involving the June 2022 grocery store incident—was set for
January 31, 2024.
By that hearing, Williams still had not participated in an independent examination.
Defense counsel instead requested to proceed to a contested competency hearing without
one, suggesting “a couple of months out.” A hearing was set for March 25 but did not take
4
place because, according to the district court’s later summary, another competency
examination was completed in February in another (again unspecified) county and “nobody
liked” the report.
Instead, on March 1, the district court ordered a competency examination in this
matter. Two months later, the court-appointed examiner reported she had been unable to
contact Williams to conduct an examination, despite repeated efforts, and said that she
would need to be reappointed to allow additional time to examine him. The district court
reissued its order for a competency examination. The examiner submitted a report on June
10, opining that Williams was competent to proceed. The district court adopted the opinion
without objection and found Williams competent. Progress toward trial resumed.
Pretrial Proceedings
A pretrial hearing was set for July 8. Before that hearing, Williams was assigned
new counsel and asked for a continuance to allow them time to meet. The district court
granted the request and set a new pretrial hearing date of August 20. At that hearing,
Williams appeared wi th counsel and demanded a speedy trial, and the court set a trial-
management conference for October 3, to be followed by a jury trial starting October 14.
At the October 3 hearing, Williams asked to discharge his attorney. T he district
court denied the request, noting that Williams seemed frustrated with the court, not counsel,
but provided him a petition to proceed pro se.
At the next hearing, on October 14, the district court reminded Williams that it had
provided him the petition and asked if he still wanted to discharge his attorney. He said he
did not. Defense counsel then noted that because of the uncertainty regarding a possible
5
waiver of counsel she was delayed in filing “certain things” and, at the court’s request,
agreed to file them that day. Counsel filed a motion to dismiss “for violation of right to
speedy trial due to ineffective assistance of counsel,” asserting that Williams’s first
attorney “made a frivolous request” for a competency evaluation, which caused
“unreasonable delay that violated [his] right to a speedy trial.” Counsel also noted that,
because of the nature of the motion, the public defender’s office would need to appoint a
conflict attorney, which would necessitate a continuance.
The district court found “good cause to continue this matter” to resolve the motion
with “a conflicts lawyer.” The district court heard the motion on November 7 and denied
it that day, explaining that the fact that Williams was found competent did not make defense
counsel’s request for a competency examination frivolous or otherwise indicative of
ineffective assistance of counsel because that is the result of most competency
examinations. Rule 20.01, the court explained, serves “as a check to make sure an
incompetent defendant does not go to trial.” The court set trial for the following month.
Trial
When Williams appeared for trial on December 16, he submitted an executed
petition to proceed pro se and told the court he wanted to represent himself. The district
court started questioning Williams about his waiver of counsel but paused and recalled the
matter twice because of his uncooperative behavior, including shouting when asked to
speak up and interrupting the judge. In its third effort, the district court spoke with
Williams extensively (spanning more than 60 transcript pages) about his decision to waive
counsel. During that exchange, Williams repeatedly focused on the competency
6
proceedings and said he was being forced to proceed pro se. Ultimately, though, Williams
said he was voluntarily waiving counsel and agreed that he understood that “once [the
court] discharge[d] the Public Defender’s Office, they [would] not be reappointed to
represent [him].” The district court found that he had “freely, voluntarily, and knowingly”
waived counsel and accepted his petition to proceed pro se. The court appointed standby
counsel, to which Williams agreed, also acknowledging that he understood her “role is
limited.”
As the court then discussed evidentiary matters with Williams and the prosecutor,
Williams began requesting an examination for a mental-illness defense under Minn. R.
Crim. P. 20.02, which the district court denied, finding that he was merely trying to delay
trial. The court noted that Williams could still argue to the jury regarding his mindset at
the time of the alleged offenses.
The next day, the court noted that jury selection would happen that afternoon and
resumed discussion of evidentiary matters. Williams asserted that he was “not up to par to
represent [himself] appropriately right now” because he had not received enough to eat and
refused to change into street clothes because he had not been able to shower and shave. He
also renewed his request for a rule 20.02 examination, which the district court again denied,
with additional explanation. Discussion of motions in limine followed, during which
Williams repeatedly interrupted the court and refused to respond to questions. The court
admonished him for “disrupting this trial from going on” and advised him that it would
give him three warnings and would “remove [him] from this trial” if his “disruptive”
behavior continued.
7
Williams then asked for a copy of the most recent rule 20.01 report, and the court
instructed him to stop talking about rules 20.01 and 20.02, and if he did not the court would
“deem it a disruption to this trial.” At this point, Williams requested that standby counsel
“step in for [him]” and “take over the case.” The district court denied the request. Williams
also asked the court to “give [him] a Public Defender,” which the court denied.
Williams resumed complaining of his mental state, but the district court found him
“alert” and exhibiting no indication of incompetence but rather knew “very well what he’s
doing, which is to stall jury selection.” When Williams’s commentary about competency
continued after a “final warning,” the court had him removed from the courtroom. It
completed motions in limine in his absence, then had Williams returned to the courtroom.
Williams continued to interrupt and reference rule 20, and the court had him removed
again. The court offered Williams another chance to return to court before starting jury
selection; he declined. Standby counsel participated in jury selection but confirmed that
she would thereafter resume a “back seat” role.
When testimony began the following day, December 18, Williams refused transport
from jail. The trial proceeded without him. The jury found Williams guilty on all three
counts, and the court sentenced him to time served.
Williams appeals.

8
DECISION
The United States and Minnesota Constitutions afford every criminal defendant a
host of rights, which sometimes conflict with each other. Defendants have the right to a
speedy trial. U.S. Const. amend. VI; Minn. Const. art. I, § 6. But they also have a right
not to be tried while legally incompetent, and a district court must “observe procedures
adequate to protect [this] right,” including suspending proceedings—thereby delaying
trial—if there is reason to doubt a defendant’s competency. Bonga, 797 N.W.2d at
718 (quoting Drope v. Missouri, 420 U.S. 162, 171 (1975)). Similarly, defendants have
the right to assistance of counsel, b ut they also have the “corollary” right to represent
themselves, which can create a “ dilemma” for courts, particularly if a defendant waives
their right—also constitutionally protected—to be present for trial. State v. Worthy, 583
N.W.2d 270, 277, 279 (Minn. 1998); see Ford v. State, 690 N.W.2d 706, 712 (Minn.
2005) (discussing defendant’s constitutional right to be present at trial). This case lies at
the crossroads of these rights.
I. Williams’s right to a speedy trial was not violated.
We review de novo whether a defendant’s speedy trial right was violated.
State v. Jones, 977 N.W.2d 177, 190 (Minn. 2022). In doing so, we consider four
nonexclusive factors: (1) the length of the delay, (2) the reason for the delay, (3) the
defendant’s assertion of the right to a speedy trial, and (4) the prejudice to the defendant as
a consequence of the delay. State v. Zielinski, 10 N.W.3d 1, 17 (Minn. 2024) (citing
Barker v. Wingo, 407 U.S. 514, 530 (1972)). We view the factors together, along with any
other relevant circumstances, in a “difficult and sensitive balancing process” in which no
9
single factor is necessary or sufficient to a conclusion that the defendant was deprived of
the right to a speedy trial. State v. Mikell, 960 N.W.2d 230, 245 (Minn. 2021) (quotation
omitted).
Length of the Delay
The length of delay is measured from the point at which the speedy trial right
attaches—the date of charging or arrest, whichever comes first. State v. Osorio, 891
N.W.2d 620, 627 (Minn. 2017). A delay of six months after that point is “presumptively
prejudicial.” Id. at 628. A delay of more than 60 days after the defendant demands a
speedy trial also establishes presumptive prejudice. Mikell , 960 N.W.2d at 246 ; see also
Minn. R. Crim. P. 11.09(b) (requiring district court to begin trial within 60 days after
speedy trial demand “unless the court finds good cause for a later trial date”). Williams
emphasizes that more than 29 months passed between charging in July 2022 and trial in
December 2024, and the state concedes that “a great deal of time” passed before Williams’s
trial. We agree. But even presumptively prejudicial delay is not dispositive; it merely
“trigger[s] an inquiry into the remaining Barker factors.” Osorio, 891 N.W.2d at 628.
Reason for the Delay
We also consider whether the state (the prosecution and the courts) or the defendant
is responsible for the delay. Mikell, 960 N.W.2d at 250-51. “When the overall delay in
bringing a case to trial is the result of the defendant’s actions, there is no speedy trial
violation.” Id. (quotation omitted). Delay is attributed to the defendant when it results
from defense motions, including a motion for a competency evaluation. State v. DeRosier,
695 N.W.2d 97, 109 (Minn. 2005).
10
The bulk of the delay in bringing this matter to trial is undisputedly because of the
competency process that stretched from June 2023 to June 2024. Williams faults the
district court for this delay, asserting that the court mismanaged the process. We disagree.
More than eight months of proceedings sprung from defense counsel’s requests—first for
an independent examination, then for a contested competency hearing. These requests are
reasonably attributable to Williams. Id. Then the district court ordered a competency
examination in March 2024, which did not occur until three months later because Williams
would not make himself available to the examiner. In short, the entire competency-related
delay is attributable to Williams.
Once that process ended, there was a brief delay for Williams’s new counsel to
prepare, which we consider neutral because Williams did not request the substitution. But
then further defense delays followed, pushing trial from October 2024 to December 2024—
Williams’s request to dismiss defense counsel, then a defense motion to dismiss that
counsel was delayed in filing because of Williams’s interest in dismissing her, followed by
a brief delay to appoint conflict counsel, then a hearing on the motion where the court
promptly denied it, permitting progress toward trial to resume. Because the record reflects
extensive delay attributable to Williams, and he cannot point to any delays caused by the
state, this factor weighs heavily against him.
Assertion of the Right
An assertion of the speedy trial right is determined based on the circumstances.
State v. Windish, 590 N.W.2d 311, 317 (Minn. 1999). The question is not whether the
defendant made a “formal or technical” demand for a speedy trial but merely whether they
11
took “any action what soever that could be construed as the assertion of the speedy trial
right.” Id. (quotation omitted). But the relevant circumstances also include any conduct
by the defendant after demanding a speedy trial that suggests the defendant’s demand was
not “serious.” Mikell, 960 N.W.2d at 252. “[S]uch an assessment focuses on whether the
speedy-trial demands are accompanied by actions that undermine the ability for the trial to
occur.” State v. Paige, 977 N.W.2d 829, 841 (Minn. 2022).
Williams says that he demanded a speedy trial on November 15, 2022, while the
state insists that he did not do so until August 20, 2024. We agree with Williams. At the
earlier hearing, Williams said that he had “asked for a speedy trial before . . . coming in
here” and “always ask[s] for a speedy trial.”
While these comments are not a formal invocation of his speedy trial right, it is hard
to construe them as anything other than a request for a speedy trial. But Williams followed
his assertion of the right by refusing to cooperate with the competency process. And while
he reasserted his speedy trial right after being found competent, he prioritized other
matters—in particular, moving to dismiss based on a claim that the competency process
violated his speedy trial right, rather than simply proceeding expe ditiously to trial. See
Mikell, 960 N.W.2d at 253 (distinguishing between moving to dismiss based on claimed
speedy trial violation and requesting a speedy trial). Overall, this factor weighs somewhat,
but not overwhelmingly, in favor of Williams.
Prejudice
We consider three interests in determining whether a defendant suffered prejudice:
“(1) preventing oppressive pretrial incarceration; (2) minimizing the anxiety and concern
12
of the accused; and (3) preventing the possibility that the defense will be impaired.”
State v. Taylor, 869 N.W.2d 1, 20 (Minn. 2015) (quotation omitted). Williams does not
claim any impairment of his defense but contends he was prejudiced by the delay in
bringing this matter to trial because he was subjected to more than 300 days of pretrial
incarceration. But the interest in preventing “oppressive pretrial incarceration” is “not
implicated” if the defendant is “already in custody for another offense.” Id. Our careful
review of the record confirms that Williams spent significant time in custod y during the
pendency of these charges but all of it because of other offenses. Williams faced numerous
other charges, including gross misdemeanors and felonies, in Ramsey County and
elsewhere throughout the pendency of this matter, and he was often in custody because of
those other charges.1 However, Williams does not identify, and our careful review has not
revealed, anything in the record that indicates Williams was ever in custody for the
misdemeanor charges in this matter. Williams’s complaint of anxiety and concern over the
delay is similarly unsubstantiated because he cites merely generalized “frustration and
concern over the trial delay.” On this record, the prejudice factor does not suggest a speedy
trial violation.
Balancing
The delay of more than 29 months in bringing this matter to trial undisputedly raises
a presumption of prejudice, but the other factors do not favor Williams’s speedy trial claim.

1 The competency proceedings at issue here also pertained to those other charges, and the
examination report in June 2024 was for this and seven other Ramsey County cases.

13
Defense motions contributed to most of the delay and also cast some doubt on the
seriousness of Williams’s assertion of his speedy trial right, and the record does not indicate
any prejudice to Williams. Accordingly, Williams’s speedy trial claim fails.
II. Williams is not entitled to relief based on the district court’s management of
the competency proceedings.

Williams contends the district court committed “pervasive errors” in the
competency proceedings by failing to comply with Minnesota Rule of Criminal Procedure
20.01 (2022).2 He first claims error in the district court’s adoption of the Dakota County
competency report, arguing it was improper because no statute or rule authorizes it to do
so. We are not persuaded. While r ule 20.01 does not expressly permit a district court to
adopt a competency report from another county, nor does it prohibit a court from doing so.
Moreover, the rule contemplates information sharing. See Minn. R. Crim. P. 20.01, subd.
4(a) (“Any examiner may obtain and review the report of any prior examination under this
rule.”). And courts are charged with “maintaining an efficient and effective judicial
system.” State v. Courtney, 696 N.W.2d 73, 82 (Minn. 2005). We discern no error in the
district court’s efficient use of the Dakota County report here.

2 Williams discusses the requirements of Minn. Stat. §§ 611.40-.59 (2024) and the current
version of Minnesota Rule of Criminal Procedure 20.01. But neither those statutes nor the
current version of rule 20.01 were in effect during the competency proceedings in this
matter. 2023 Minn. Laws, ch. 52, art. 1, § 14 (providing that new competency statutes are
effective April 1, 2024, and “apply to competency determinations initiated on or after that
date”); Order Promulgating Amendments to the Minn. Rules of Criminal Procedure, No.
ADM10-8049 (Minn. Sept. 20, 2024) (providing that amendments to rule 20.01 to account
for the new competency statutes are effective November 1, 2024). Accordingly, we limit
our analysis to the applicable version of rule 20.01.
14
Williams also contends the court “unjustifiably suspended” proceedings based on
the Dakota County competency report and “mishandled” the defense request for an
independent examination. This contention is also unavailing. A district court that finds
reason to doubt a defendant’s competency must “suspend the criminal proceedings,” order
a competency examination (unless dismissal is warranted), and set a hearing for “no later
than 60 days from the date of the court’s order.” Minn. R. Crim. P. 20.01, subd. 3. But
between June 2023 and March 2024, the district court never found reason to doubt
Williams’s competency and never issued an order or made a statement on the record that
it was suspending the proceeding. Rather, the court granted defense requests for time to
obtain an independent competency evaluation. And while rule 20.01 requires a party
objecting to a competency report to do so within 10 days, it does not establish a time limit
for obtaining an independent examination or preclude a court from granting continuances
to accommodate that process. See Minn. R. Crim. P. 20.01, subd. 5.
Williams also fault s the district court’s March 2024 order for a competency
evaluation as stating insufficient basis for doubting his competency. He is correct that the
order itself is somewhat vague, citing only “the record, including the motion(s) and
representations of counsel, as well as the Court’s observations of the defendant.” But he
does not identify any authority requiring the district court’s order to say more than that.
Also, the record does, in fact, supply reason to doubt Williams’s competency in the form
of (1) consistent and undisputed recognition that multiple other courts had issued orders
questioning Williams’s competency; and (2) defense counsel’s objection, sustained over
15
more than eight months, to the district court’s acceptance of the Dakota County evaluation
finding him competent.
In sum, Williams has not demonstrated that the district court committed any errors
in its management of the competency proceedings.
III. The district court did not abuse its discretion by refusing to reappoint counsel
and trying Williams in absentia.

Williams contends the district court erred by denying his request to have counsel
reappointed and trying him in absentia, emphasizing the constitutional rights to have the
assistance of counsel and to be present for trial. See United States v. Cronic, 466 U.S. 648,
654 (1984) (counsel); Ford, 690 N.W.2d at 712 (presence); see also Minn. R. Crim. P.
26.03, subd. 1(1) (presence). But , as he also acknowledges, both of these rights can be
waived. Minn. R. Crim. P. 26.03, subd. 1(2) (presence); State v. Finnegan, 784 N.W.2d
243, 247 (Minn. 2010) (presence); Worthy, 583 N.W.2d at 275 (counsel). And both of the
decisions he challenges are discretionary ones. We address each in turn.
Reappointment of Counsel
A defendant who waives counsel “does not have an absolute right to relinquish the
right of self-representation.” State v. Clark, 722 N.W.2d 460, 469 (Minn. 2006) . They
may do so only if the request is “timely, reasonable, and reflects extraordinary
circumstances.” Id. The district court has discretion whether to grant the request and, in
exercising that discretion, should balance “the request against the progress of the trial to
date, the readiness of standby counsel to proceed, and the possible disruption of the
proceedings.” Id. (quotation omitted).
16
Here, Williams claims error in the district court’s refusal to reappoint counsel. The
record shows otherwise. Williams asked to relinquish self-representation the day after he
waived counsel and in the midst of final trial preparations, as the court was addressing
motions in limine and attempting to proceed with jury selection. The district court also
repeatedly rejected Williams’s claim that he could not represent himself because he was
lacking “energy” and “mental stability,” finding that he was “fully engaged” and “alert”
and merely intended to delay trial. And as Williams acknowledges, reappointment of
counsel, whether through standby counsel or a public defender, would have necessitated a
continuance. Given the age of the case (which Williams himself emphasizes) and the
numerous hurdles already overcome to bring the case to the eve of trial, as well as the
district court’s express findings regarding Williams’s mental state, we discern no abuse of
discretion in the district court’s denial of Williams’s request to reappoint counsel.
Trial in Absentia
Notwithstanding the defendant’s right to be present during trial, a district court may
conduct trial in their absence if (1) the defendant is “absent without justification after the
trial starts”; or (2) the defendant “after warning, engages in conduct that justifies expulsion
from the courtroom because it disrupts the trial or hearing.” Minn. R. Crim. P. 26.03, subd.
1(2). If a court excludes a defendant for disruptive behavior, it need not “continually”
invite them back or otherwise seek to determine if they are “ready to behave.”
State v. Gillam, 629 N.W.2d 440, 452 (Minn. 2001). Rather, “the defendant has the burden
to inform the court” when they are ready to return and “conform [their] conduct to the
requirements of the court.” Id. We review the “decision to conduct a trial in absentia under
17
an abuse of discretion standard and will not disturb the [district] court’s factual findings
unless they are clearly erroneous.” Id. at 450.
Williams advances several arguments challenging the district court’s decision to
remove him and conduct trial without him. First, he argues that his conduct was not
disruptive because it was “primarily” focused on requesting a rule 20.02 examination and
such a focus was appropriate because the district court improperly conflated rules 20.01
and 20.02 in denying the request. This argument is unavailing. The behavior the district
court found disruptive was not only— or even primarily —requests for a rule 20.02
examination. Rather, as the district court noted, various aspects of Williams’s behavior
were disruptive, including repeatedly interrupting the court, refusing to answer questions,
and referencing rule 20.01. Also, even if he were correct about the merits of the district
court’s reasoning in denying his request for a rule 20.02 examination, he identifies no
authority for the proposition that it is appropriate, rather than disruptive, to repeat such
requests in the face of multiple express rulings and multiple warnings to desist.
Williams also seeks to minimize his disruptive behavior by noting that it did not
occur in the jury’s presence. But a defendant may be removed for disruptive behavior even
before a jury is sworn if trial is scheduled to begin and prospective jurors are waiting for
jury selection. Carse v. State, 778 N.W.2d 361, 369 (Minn. App. 2010), rev. denied (Minn.
Apr. 20, 2010). That was the circumstance here.
Finally, Williams emphasizes that removing him from the courtroom left nobody to
advocate for him and counter the state’s case. He contends doing so “in tandem” with
denying his request to reappoint counsel “led to a fundamentally unfair process.” But
18
Williams largely ignores that the lack of an adversarial element during the state’s
presentation of evidence was due to his refusal to come to court, not the district court
excluding him. Williams seems to assert that his absence was involuntary, but he has the
burden to prove as much. State v. Finnegan, 784 N.W.2d 243, 247 (Minn. 2010). He has
not done so. He says only that the record is “complicated,” and does not address either
instance in the record when the district court invited Williams to return to court and he
expressly refused. Additionally, the supreme court has determined that a defendant may
waive the right to be present even if they have also waived counsel, leaving nobody in the
courtroom actively representing their interests. Worthy, 583 N.W.2d at 277, 279.
On this record, the district court did not abuse its discretion by conducting
Williams’s trial in his absence.
IV. Williams is not entitled to relief based on his pro se arguments.
In a pro se supplemental brief, Williams asserts claims of judicial bias, error in jury
instructions, and error in the exclusion of a witness. We address each in turn.
Judicial Bias
On the first scheduled day of trial, in the midst of discussing his counsel waiver,
Williams asserted that the presiding judge was biased and asked her to remove herself. He
cited a pretrial hearing in August 2024 at which the judge had presided and asked the parties
whether they had resolved the case, asserting that encouraging them toward a resolution
“prejudged the case.” The district court denied the request, explaining that it is common
to inquire about case resolution, in part to ensure defendants are aware of and consider their
options. Williams reiterated his claim of judicial bias the next day, citing “the same
19
reason.” Later that day, the chief judge questioned Williams about his bias claim, to which
he added that the presiding judge had removed him from the courtroom and “belittled” him
and been “sarcastic” toward him. The chief judge denied the claim, noting that adverse
rulings are not grounds to remove a judge for bias and finding that the judge could “preside
over this trial, that she can do so judiciously, impartially, and respectfully.”
Williams challenges the denial of his disqualification motion. We review the denial
of a motion to disqualify a judge for an abuse of discretion. Rossberg v. State, 874 N.W.2d
786, 789 (Minn. 2016). “Judicial bias is a basis for disqualification,” but a party’s
“subjective belief that the judge is biased does not necessarily require disqualification.” Id.
To demonstrate bias, Williams reiterates his concerns about the presiding judge’s earlier
inquiry about a resolution. But he cites no authority precluding a judge from asking about
case resolution, and the rules contemplate such an inquiry. See Minn. R. Crim. P. 11.05
(“The Omnibus Hearing may also include a pretrial conference to determine whether the
case can be resolved before trial.”). He also complains of unspecified “misconduct” during
trial, which seems to be a repetition of his complaint about adverse rulings. But “adverse
rulings by themselves do not demonstrate judicial bias .” Hannon v. State, 752 N.W.2d
518, 522 (Minn. 2008). On this record, Williams has not shown an abuse of discretion in
denying his motion to disqualify the presiding judge for judicial bias.
Jury Instructions
Williams also argues that the district court erred in its jury instructions on fifth-
degree assault. Where, as here, there was no objection to the instruction at trial, we review
for plain error. State v. Collins, 24 N.W.3d 693, 704 (Minn. App. 2025), rev. denied (Minn.
20
Sept. 17, 2025). Under that standard, we will reverse only if (1) an error occurred, (2) it is
“plain” or “obvious,” (3) it affected substantial rights, and (4) it “ seriously affects the
fairness, integrity, or public reputation of judicial proceedings.” Id. at 704-05.
Williams contends the district court erred in instructing the jury on the elements of
fifth-degree assault because it said only that the offense entails intentional infliction of
bodily harm, omitting an instruction about an attempt to inflict bodily harm. He notes that
the pattern jury instructions contemplate a possible instruction on attempt, 10 Minnesota
Practice, CRIMJIG 8.17 (2022), and that the jury asked a question about the instruction:
“Does bodily harm have to occur or is it just the intent to cause bodily harm?” But the
state charged Williams with an actual assault—striking a person in the face—not an
attempt, so instructing the jury on attempt likely would have been more confusing than
helpful. See Collins, 24 N.W.3d at 706 (stating that when the charge was assault, rather
than attempted assault, failing to define “assault” as part of instructions “might have
confused rather than guided the jury”). We discern no error in declining to give such an
instruction. Moreover , the jury’s guilty verdict reflects its determination that the state
proved that Williams did not merely attempt but actually inflicted bodily harm, so any error
in omitting the instruction did not affect his substantial rights.
Exclusion of Defense Witness
Williams also contends the district court erred by “not allowing” a witness he
wanted to call. We review a district court’s evidentiary rulings for an abuse of discretion.
State v. Maye, 6 N.W.3d 103, 108 (Minn. 2024). The district court excluded D.M.’s
proposed testimony because he was undisputedly not present at the time of the alleged
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offenses and, therefore, lacked personal knowledge of the events in question. Because
witnesses may only testify to matters within their personal knowledge, Minn. R. Evid. 602,
the district court did not abuse its discretion by excluding the witness.
Affirmed.