Cited by

Opinions in Minnesota that cite State v. Wofford, 114 N.W.2d 267.

94 citing documents.

State of Minnesota v. Deshon Israel Bonnell Minn. 2026
State of Minnesota v. Deshon Israel Bonnell Minn. 2026
First, evidence of a prior bad act is admissible as immediate-episode evidence “where two or more [crimes, wrongs, or acts] are linked together in point of time or circumstances so that one cannot be fully shown without proving the other.”
State of Minnesota v. Edward James Lafore, Jr. Minn. Ct. App. 2025
State of Minnesota v. Edward James Lafore, Jr. Minn. Ct. App. 2025
18 offense with which the accused is charged, even though such facts and circumstances may prove or tend to prove that the defendant committed other crimes.”
State of Minnesota, Respondent, Minn. Ct. App. 2025
Under the immediate -episode rule, “[t]he state may prove all relevant facts and circumstances which tend to establish any of the elements of the offense with which the accused is charged, even though such facts and circumstances may prove or tend to prove that the defendant committed other crimes.”
State of Minnesota, Respondent, Minn. Ct. App. 2024
2 Immediate-episode evidence, also referred to as “intrinsic evidence,” is admissible, even though such evidence may relate to another crime, when “two or more offenses are linked together in point of time or circumstances so that one cannot be fully shown without proving the other, or where evidence of other crimes constitutes part of the res gestae.”
State of Minnesota v. Jamal L. Smith 9 N.W.3d 543 Minn. 2024
State of Minnesota v. Jamal L. Smith 9 N.W.3d 543 Minn. 2024
State of Minnesota, Respondent, Minn. Ct. App. 2022
State of Minnesota, Respondent, Minn. Ct. App. 2021
Heiderscheid challenges this evidence as unnoticed and 3 prejudicial Spreigl evidence.1 But the state may “prove all relevant facts and circumstances” of the immediate episode of the charged offense, “even though such facts and circumstances may prove or tend to prove that the defendant committed other crimes.”
State of Minnesota, Respondent, Minn. Ct. App. 2021
A19-1493 Minn. Ct. App. 2020
In State v. Wofford , the supreme court recognized the admissibility of one type of intrinsic evidence: immediate episode evidence.
State of Minnesota, Respondent, Minn. Ct. App. 2019
State v. Wofford , (M inn.
State of Minnesota, Respondent, Minn. Ct. App. 2019
State of Minnesota, Respondent, Minn. Ct. App. 2019
(stating that we assume that jurors accused is charged, even though such facts and circumstances may prove or tend to prove that the defendant committed other crimes.”
State of Minnesota, Respondent, Minn. Ct. App. 2019
Not all references to prior bad acts constitute Spreigl evidence, and immediate-episode evidence is admissible “when there is a close causal and temporal connection between the prior bad act and the charged crime .” , 425 (Minn. 2009) ; see State v. Wofford , (“It is well recognized that the rule excluding evidence of the commission of other offenses does not necessarily deprive the state of the right to make out its whole case against the accused on any evidence which is otherwise relevant upon
State of Minnesota, Respondent, Minn. Ct. App. 2019
State of Minnesota, Respondent, Minn. Ct. App. 2018
See, e.g., State v. Wofford , (“[W]here two or more offenses are linked together in point of time or circumstances so that one cannot be fully shown without proving the other, or where evidence of other crimes constitutes part of the res gestae , it is admissible.”); State v. Walsh , (“Arguabl
State of Minnesota, Respondent, Minn. Ct. App. 2018
See State v. Riddley , -27 (Minn. 2009); State v. Wofford, 262 Minn. 112, 117-18
State of Minnesota, Respondent, Minn. Ct. App. 2017
“[T]he rule excluding evid ence of the commission of other offenses does not necessarily deprive the state of the right to make out its whole case against the accused on any evidence which is otherwise relevant upon the issue of the defendant’s guilt of the crime with which he was c harged.” State v. Wofford, 262 Minn. 112, 118
State of Minnesota, Respondent, Minn. Ct. App. 2017
See State v. Riddley , d 419, 424-27 (Minn. 2009); State v. Wofford , 262 Minn. 112, 118
State of Minnesota v. Marco Anthony Gresham Minn. Ct. App. 2016
State of Minnesota v. Marco Anthony Gresham Minn. Ct. App. 2016
Such evidence is admissible “where two or more offenses are linked together in point of time or circumstances so that one cannot be fully shown without proving the other, or where evidence of other crimes constitutes part of the res gestae.” State v. Wofford, 262 Minn. 112, 118
State of Minnesota v. Diamond Lee Jamal Griffin 887 N.W.2d 257 Minn. 2016
Rene Julian McKenzie v. State of Minnesota 872 N.W.2d 865 Minn. 2015
Rene Julian McKenzie v. State of Minnesota 872 N.W.2d 865 Minn. 2015
(quoting State v. Wofford, 262 Minn. 112, 115, ).
State of Minnesota v. Elvis Joko Porte Minn. Ct. App. 2015
State of Minnesota v. Elvis Joko Porte Minn. Ct. App. 2015
The res gestae exception to the general prohibition on other-bad- acts evidence allows the state to offer evidence of crimes other than the ones charged “where two or more offenses are linked together in point of time or circumstance so that one cannot be fully shown without proving the other.” State v. Wofford, 262 Minn. 112, 118
State of Minnesota v. Earvin Ainwin Wright Minn. Ct. App. 2014
State of Minnesota v. Earvin Ainwin Wright Minn. Ct. App. 2014
Under this exception, “[t]he state may prove all relevant facts and circumstances which tend to establish any of the elements of the offense with which the accused is charged, even though such facts and circumstances may prove or tend to prove that the defendant committed other crimes.” State v. Wofford, 262 Minn. 112, 118
State v. Brown 815 N.W.2d 609 Minn. 2012
State v. Hormann 805 N.W.2d 883 Minn. Ct. App. 2011
State v. Hormann 805 N.W.2d 883 Minn. Ct. App. 2011
Other-crime evidence is admissible as immediate-episode evidence “where two or more offenses are linked together in point of time or circumstances so that one cannot be fully shown without proving the other, or where evidence of other crimes constitutes part of the res gestae.” State v. Wofford, 262 Minn. 112, 118 , see Riddley, d at 425-26 .
State v. Koppi 798 N.W.2d 358 Minn. 2011
State v. Koppi 798 N.W.2d 358 Minn. 2011
See, (“Where error may have prejudiced a close factual case, this court will order a new trial, even if the evidence is otherwise sufficient to support the verdict.”); State v. Wofford, 262 Minn. 112, 120 , (holding that where an error “might be expected to substantially prejudice the jury against the defendant, it should not be disregarded on the ground that the record contains sufficient other evidence to sustain the conviction”).
State v. Riddley 776 N.W.2d 419 Minn. 2009
State v. Riddley 776 N.W.2d 419 Minn. 2009
In State v. Wofford, we explained that “the rule excluding evidence of the commission of other offenses does not necessarily deprive the state of the right to make out its whole case against the accused on any evidence which is otherwise relevant upon the issue of the defendant’s guilt of the crime with which he was charged.” 262 Minn. 112, 118
State v. Reed 737 N.W.2d 572 Minn. 2007
State v. Reed 737 N.W.2d 572 Minn. 2007
“[Wjhere two or more offenses are linked together in point of time or circumstances so that one cannot be fully shown without proving the other * ⅜ * [evidence of the other offense] is admissible.” State v. Wofford, 262 Minn. 112, 118
State v. Kendell 723 N.W.2d 597 Minn. 2006
State v. Kendell 723 N.W.2d 597 Minn. 2006
The shootings in the two apartments were so closely linked that “one cannot be fully shown without proving the other”; they were “part of one transaction.” State v. Wofford, 262 Minn. 112, 118 , -72 (1962).
Pederson v. State 649 N.W.2d 161 Minn. 2002
Pederson v. State 649 N.W.2d 161 Minn. 2002
(citing State v. Wofford, 262 Minn. 112, 115 , -70 (1962)).
State v. Nunn 561 N.W.2d 902 Minn. 1997
State v. Nunn 561 N.W.2d 902 Minn. 1997
Nunn contends that, by admitting K. Nunn’s testimony regarding the ride in the park, the trial court admitted “other crimes” evidence in violation of this court’s holding in State v. Wofford, 262 Minn. 112 , (other crimes evidence generally inadmissible to prove crime for which defendant is on trial).
McDonnell v. Commissioner of Public Safety 460 N.W.2d 363 Minn. Ct. App. 1990
State v. Mosby 450 N.W.2d 629 Minn. Ct. App. 1990
State v. Mosby 450 N.W.2d 629 Minn. Ct. App. 1990
State v. Wofford, 262 Minn. 112, 118
State v. Larson 447 N.W.2d 593 Minn. Ct. App. 1989
State v. Larson 447 N.W.2d 593 Minn. Ct. App. 1989
Logically, if due process requires a fair trial, State v. Wofford, 262 Minn. 112, 120 , and a fair trial requires the rights of confrontation and cross-examination, Lee v. Illinois, 476 U.S. 530, 540 , 106 S.Ct.