The 2024 Season Case is Here
An Introduction from the Case Committee Chairs
Introduction: A Crime in the Courtroom
“Do you solemnly affirm that the testimony you are about to give in the matter pending before this court will be
the truth, the whole truth, and nothing but the truth under penalty of perjury?”
“I do.”
“Please take a seat, then state and spell your name for the record.”
“Jaylen Burgess. J-A-Y-L-E-N, B-U-R-G-E-S-S.”
On June 20, 2016, Jaylen Burgess looked twelve jurors in the eyes and testified that they were an eyewitness
to a murder. They testified that they were at the scene of the crime, that they witnessed the crime, and that they
identified the shooter as the defendant, Matthew Reese.
Four days later, the jury came back with a verdict: Guilty. Matthew Reese was sentenced to life in prison for the
murder of Tyler Larson.
But there was a problem. It wasn’t true. None of it was true. Matthew Reese was innocent.
The truth was that Jaylen Burgess wasn’t at the scene of the crime at all. Jaylen Burgess didn’t actually see the
shooting. And Jaylen Burgess never identified the shooter.
But the truth wasn’t revealed until five years later, in 2021, when Jaylen Burgess came forward and admitted that
they lied in their interview with the police and lied during their testimony at the jury trial.
And then, Burgess revealed much, much more. Burgess said that their testimony was coerced, coached, and
paid for – by the elected sheriff of Esseph County, Michelin Klein. Burgess acknowledged that what they did was
wrong, but they only did it because they were desperate. As the unhoused parent of two young children, they
felt as though they had no choice.
As a result of Burgess’s admissions, Matthew Reese’s conviction was overturned.
But that was just the beginning. Public outrage at this miscarriage of justice led the State of Empirion to open a
formal investigation into Burgess’s claims, and in particular, Sheriff Klein’s alleged criminal conduct.
State investigators learned that the Larson murder investigation was at risk of going cold. In 2012, Klein’s office first presented their case to the Esseph County District Attorney. But the prosecutors declined to file charges.
The evidence was too weak, and there was no definitive identification of the shooter.
To make matters worse, during the investigation, Klein’s first term as the elected sheriff was marred by public criticism. Community members complained of increasing crime, misuse of tax money, and inadequate social services.
With election year 2016 fast approaching, Klein needed a win – and fast.
Just one week later, Klein arranged for Detective Mckenzie Michaels to administer a photo lineup and recorded an interview of Burgess. During the interview, Burgess provided the critical identification of the suspect, Matthew Reese.
With Burgess’s identification, Klein’s office once again presented its case to the District Attorney. This time, charges were filed. And after the conviction, Klein won reelection.
Following the investigation, the State of Empirion filed criminal charges against Michelin Klein for subornation of perjury and bribery of a witness.
The Government’s Case: A Politician With a Price Tag
For their entire career, Michelin Klein dreamed of becoming the Sheriff of Esseph County. In 2012, that dream came true. But in their role as Sheriff, Klein faced unexpected obstacles. Rising crime rates led to low approval ratings. Investigations in high-profile cases, such as the murder of Tyler Larson, were stagnant. Klein had to do something.
The Prosecution argues that Klein, driven by their desire to be reelected, interfered with the investigation into Larson’s death. However, Klein’s interference was not limited to discovering Jaylen Burgess; it was coaching Jaylen Burgess. In fact, Burgess did not witness any of what they testified to in Reese’s trial.
Witnesses observed clandestine meetings between Klein and Burgess appearing to discuss the case. Klein withdrew cash to give Burgess for their cooperation. And Burgess admits that Klein provided the money with instructions to lie on the witness stand.
Klein’s Case: An Informant With Misinformation
Michelin Klein adamantly denies these accusations. The elected sheriff has retained a top-notch team of defense attorneys, entered pleas of “not guilty,” and asserted their constitutional right to a speedy and public jury trial.
The Defense highlights Klein’s history with Jaylen Burgess. Klein acknowledges that they developed an informal community-informant relationship with Burgess. For years, Klein provided small monetary donations to Burgess, who was unhoused, to assist with costs for their family’s living needs. Most of these funds were provided in cash on occasions when they met in person.
Burgess, with the hopes of receiving more money for information about a high-profile case, approached Klein and claimed to have information about Tyler Larson’s death. Klein never offered information or coached Burgess about the facts. They just listened, then referred Burgess to Detective Mckenzie Michaels, the lead detective on the case.
For their part, Burgess never imagined the case would proceed to trial. After being subpoenaed, they began to regret their decision. And after Matthew Reese was wrongfully convicted, Burgess realized that their attempt to earn extra money had extreme consequences. That was why Burgess came forward to admit that they lied.
The Defense argues that there is an innocent explanation for all of Klein’s actions – they were misled and misinformed. Based on such flimsy circumstantial evidence, the prosecution cannot prove its case beyond a reasonable doubt.
Pre-Trial Oral Argument: Can the Government’s Witness Be Trusted?
In order for the Prosecution to meet their burden, the jury will have to believe the government’s star witness – meaning Jaylen Burgess’s credibility will be front and center at trial. But when prosecutors evaluated the evidence, they discovered that
Burgess has a criminal record: a felony conviction for animal cruelty; a misdemeanor conviction for welfare fraud; and an uncharged arrest for driving under the influence. If the jury hears about even one instance of prior misconduct, it could undermine Burgess’s credibility. And if the jury hears about more, it could undermine the government’s case.
Now, the Prosecution has filed a motion in limine to exclude evidence and argument about Jaylen Burgess’s prior bad acts. Such evidence, the State argues, is unfairly prejudicial and only admissible in narrow circumstances that do not apply here. The material is not admissible, whether for impeachment or for its substance and should be excluded.
The Defense opposes the motion, emphasizing that the government’s case rises and falls with Jaylen Burgess’s credibility. Because of this, the Defense argues that evidence of Burgess’s criminal record is highly probative for the jury to hear so they can decide whether Jaylen Burgess can be believed.
Why This Case: Public Accountability, Pillars of Justice, and Constitutional Protections
Government officials are under public scrutiny now more than ever before. Those officials receive publicity not only for being in power, but for what they do with that power. As part of Empire’s mission to educate, connect, and empower, we encourage students to consider the impact and influence of elected officials in our system of democracy. While the acts of the President and Congress often dominate the news cycle, people are more often affected everyday by the decisions of thousands of elected state, county, and local officials throughout the country. These include people such as city mayors, county supervisors, district attorneys, and sheriffs.
To that end, we encourage all Empire students to embrace their own influence as active citizens in their communities. We also encourage students to appreciate the pillars of justice that make up our criminal legal system: the presumption of innocence, the burden of proof, and proof beyond a reasonable doubt. In a criminal case, the accused is presumed to be innocent of all charges – meaning that the jury must start by assuming that the prosecution is wrong.
Similarly, the prosecution has the burden of proof – meaning it is their job to prove that the defendant is guilty and not the defendant’s job to prove their innocence. And the prosecution must prove their case beyond a reasonable doubt – meaning proof that leads the jury to conclude that the only reasonable explanation is that the defendant is guilty of the crimes charged.
These principles are the foundation of our system of justice. We challenge students to understand the significance of these principles and the important role that the rights of the accused play in all criminal prosecutions.
People accused of crimes have other important constitutional protections as well. Another unique aspect of the American criminal legal system is the Fifth Amendment privilege against self-incrimination. This means that a criminal defendant has an absolute constitutional right to remain silent throughout criminal proceedings. Because of this, a person’s silence cannot be used against them as evidence to suggest or infer their guilt.
Nonetheless, one of the most difficult issues that criminal defense attorneys grapple with every day is advising a client whether or not to testify at trial. With State v. Klein, students will step into the shoes of a practicing defense attorney and consider that decision for themselves. For the first time in Empire history, teams will face the difficult question: Should we call our client to testify in support of their own defense?
No doubt, the answer will be the product of careful consideration and advice from counsel.
We hope you enjoy State v. Klein!
Nicholas Cotter & Christian Cotter
2024 Case Committee Co-Chairs