Minor v. United States
District of Columbia Court of Appeals · 2026-06-25
Joseph Minor was convicted after a jury trial of first-degree murder while armed of Gregory Lee and related firearm offenses, based primarily on testimony from an eyewitness who knew Minor and identified him as one of the shooters during an alley argument that turned deadly. Minor appealed his convictions and the denial of his D.C. Code § 23-110 motion for a new trial, arguing that the trial court should have excluded certain statements by the victim as hearsay, that a jury instruction on aiding and abetting was improper, and that his trial counsel was ineffective for failing to investigate or call an expert on eyewitness identification. The D.C. Court of Appeals affirmed the convictions and the denial of the new-trial motion. It held that Minor had not shown plain error on the direct-appeal claims and had failed to prove deficient performance by counsel under Strickland, because his supporting affidavit was inadmissible hearsay, the eyewitness’s long familiarity with Minor reduced the relevance of stranger-identification research, and counsel could reasonably have chosen other defense strategies.