Cited by

d 167, 171-72 (Minn. 1965).

1; s (requiring the state to submit notice of intent to offer evidence of prior crimes at trial).

The judge read the following instruction: 1 Evidence of other crimes or bad acts is known in Minnesota as “Spreigl evidence.” ().

tive, intent, plan, preparation and “a propensity towards inappropriate sexual contact with young girls and is admissible to prove a common scheme or plan.” At the hearing on the motion, the state confirmed that it also sought to 1 Evidence of other crimes or bad acts is known in Minnesota as “Spreigl evidence.” ().

In December 2019, the state gave notice of its intent to introduce evidence of three other acts by Konakowitz pursuant to rule 404(b)

Altobelli 1 (stating that evidence of other misconduct may be admissible as an exception to the general prohibition against such evidence for purposes other than propensity, such as to prove motive, opportunity, intent, preparation, plan, knowledge, identity, or absence of mistake or accident).

Evidence of other crimes or bad acts is known in Minnesota as “ Spreigl evidence.” ( ).

404(b) as “Spreigl evidence” in reference to the supreme court’s

In March 2020, the state moved for leave to admit evidence of other acts pursuant to rule 404(b)

First, Smith claimed that the district court violated Minn. Stat. § 609.04 (2020), which prohibits conviction of a crime and an included offense for the same act, 3 Smith also challenged his convictions, arguing that the prosecutor committed misconduct and, additionally

State v. Ness , State v. Spreigl , d 167, 172 (Minn. 1965).

2 see also State v. Jones , (Jones I) (defining “reverse-Spreigl”).

3 The district court reasoned that A.M.’s testim ony was admissible as relationship evidence, determining that “the risk of unfair prejudice does not substantially outweigh the probative 2 (providing for the admission of prior bad acts by a defendant); Minn. Stat. § 634.20 (2018) (providing for the admission of relationship evidence).

Minnesota Rule of Evidence 404(b) govern s the admissibility of evidence of other crimes or bad acts, commonly referred to as “ Spreigl evidence.” State v. Kennedy , (citing State v. Spreigl , ).

Such evidence is commonly referred to as “ Spreigl evidence” after the supreme court’s

Minnesota Rule of Evidence 404(b) governs admission of evidence of other crimes or bad acts—commonly referred to as “ Spreigl evidence.” d 385, 389 (Minn. 1998) (citing State v. Spreigl , ).

404(b); -71 (Minn. 1965).

in order to assist [it] in determining whether [appellant] committed those acts with which [he] is charged in the complaint.” Moreover, the prejudicial effect 2 Appellant’s argument would make any evidence of a former crime with another victim inadmissible as propensity evidence, a

1 Evidence of other crimes and prior bad acts is “often referred to as Spreigl evidence after the supreme court’s decision in State v. Spreigl.” -71 (Minn. 1965); Minn. R. Evid.

police investigation of Ware relating to a different matter: “a family member of the defendant 3 alleged that he had gone through the defendant’s phone and found text messages between the defendant and his 17-year-old daughter that he found inappropriate.” The state said it was not going “to move forward with Spreigl evidence as it relates to that issue.” (emphasis added).

r, be 8 admissible for other purposes,” and provides a non -exhaustive list of such purposes including “proof of motive, opportunity, intent, preparation, plan, knowledge, identity, or absence of mistake or accident.” Evidence offered for a permissible purpose und er rule 404(b) is typically referred to as Spreigl evidence after the Minnesota Supreme Court’s

-73 (Minn. 1965) (discussing the admission of certain prior- 3 bad-acts evidence).

5 Evidence of prior crimes or other ba d acts is commonly referred to as Spreigl evidence following the supreme court’s

In Minnesota, evidence of past acts admitted in a criminal trial under rule 404(b) is typically referred to as Spreigl evidence after the Minnesota supreme court’s decision in State v. Spreigl

404(b), which allows “evidence of another crime, wrong, or act” for a purpose other than showing character, such as showing “proof of motive, opportuni ty, intent, preparation, plan, knowledge, identity, or absence of mistake or accident.”

(citing State v. Spreigl , ).