Cited by
Opinions in Minnesota that cite State v. Jones, 266 N.W.2d 706.
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State of Minnesota, Respondent,
Minn. Ct. App. 2026
D-6 medical personnel —demonstrating the severity of the harm to the victim or the lasting effect on the victim.3 3 See, 710 (Minn. 1978) (concluding “other serious bodily harm” occurred when victim testified she had ongoing numbness in teeth and treating physicians testified about injuries); - 06 (Minn. App. 1985) (concluding “other serious bodily harm” occurred where “surgical scar remain
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State of Minnesota, Respondent,
Minn. Ct. App. 2025
Moreover, “[w]hen a defendant has previously been represented by counsel, a district court ‘can reasonably presume that the benefits of legal assistance and the risks of proceeding without it have been described to [the] defendant in detail.’” ().
- Bradford Cain Dopkins v. State of Minnesota Minn. Ct. App. 2024
- Bradford Cain Dopkins v. State of Minnesota Minn. Ct. App. 2024
- State of Minnesota v. Shane Ryan Oneil Minn. Ct. App. 2024
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State of Minnesota v. Shane Ryan Oneil
Minn. Ct. App. 2024
When a defendant has consulted with an attorney prior to waiver, the district court can “reasonably presume that the benefits of legal assistance and the risks of proceeding without it [have] been described to defendant in detail by counsel.”
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State of Minnesota, Respondent,
Minn. Ct. App. 2023
“When a defendant has consulted with an attorney prior to w aiver, a [district] court could ‘reasonably presume that the benefits of legal assistance and the risks of proceeding without it had been described to defendant in detail by counsel.’” Worthy, d at 276 (quoting State v. Jones , ).
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State of Minnesota, Respondent,
Minn. Ct. App. 2023
“When a defendant has consulted with an attorney prior to waiver, a [district] court could ‘reasonably presume that the benefits of legal assistance and the risks of proceeding without it had been described to defendant in detail by counsel.’” Worthy, d at 276 ().
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State of Minnesota, Respondent,
Minn. Ct. App. 2023
ounsel on the waiver decision beyond ‘did [appellant] talk’ to counsel.” But “[w]hen a defendant has consulted with an attorney prior to waiver, a trial court could ‘reasonably presume that the benefits of legal assistance and the risks of proceeding without it had been described to defendant in detail by counsel.’” ().
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State of Minnesota, Respondent,
Minn. Ct. App. 2023
Moreover, “[w]hen a defendant has consulted with an attorney prior to waiver, a trial court could ‘reasonably presume that the benefits of legal assistance and the risks of proceeding without it had been described to defendant in detail by counsel.’” Worthy, d at 276 (); (observing that Minnesota’s appellate courts have upheld waivers of counsel despite inadequate on-the-record inquires when defendants have had “either extensive contact with defense attorneys or stand-by counsel or both”).
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A22-1093
Minn. Ct. App. 2023
“When a defendant has consulted with an attorney prior to waiver, a [district] court could ‘reasonably presume that the benefits of legal assistance and the risks of proceeding without it had been described to defendant in detail by counsel.’” Worthy, d at 276 ().
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State of Minnesota, Respondent,
Minn. Ct. App. 2023
“When a defendant has consulted with an attorney prior to waiver, a [district] court could ‘reasonably presume that the benefits of legal assistance and the risks of proceeding without it had been described to defendant in detail by counsel.’” Worthy, d at 276 ().
- State of Minnesota, Respondent, Minn. Ct. App. 2022
- State of Minnesota, Respondent, Minn. Ct. App. 2022
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State of Minnesota, Respondent,
Minn. Ct. App. 2020
at 276 (quoting State v. Jones , ); see also Thronblad , d at 263 (stating that it may be presumed that counsel representing a defendant at a waiver proceeding advised the 9 defendant so that he could make an informed decision even when the district court failed to adequately question the defendant on the record).
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State of Minnesota, Respondent,
Minn. Ct. App. 2020
But the specific princip le stated in Worthy is: “When a defendant has consulted with an attorney prior to waiver , a trial court could ‘reasonably presume that the benefits of legal assistance and the risks of proceeding without it had been described to defendant in detail by counsel.’” d at 276 () (emphasis added).
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State of Minnesota, Respondent,
Minn. Ct. App. 2020
[and] did not regain consciousness until the following day.” d 706, 710 (Minn. 1978).
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State of Minnesota, Respondent,
Minn. Ct. App. 2019
n.1 (Minn. 1978) (“[W]e strongly encourage trial courts to liberally use the authority provided in Rule [5.04], subd.
- State of Minnesota v. Patrick Michael Aleman Minn. Ct. App. 2016
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State of Minnesota v. Patrick Michael Aleman
Minn. Ct. App. 2016
(concluding that the following injuries constituted other serious bodily harm: loss of consciousness, numbness in her leg for several weeks, dizziness and headaches until just before trial, and numbness in her teeth at trial); (concluding th
- State of Minnesota v. Scotty William Polchow Minn. Ct. App. 2016
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State of Minnesota v. Scotty William Polchow
Minn. Ct. App. 2016
d 706, 710 (Minn. 1978) (concluding that a victim’s injuries constituted “other serious bodily harm” where she was found unconscious and on the verge of shock, did not regain consciousness until the next day, and remained hospitalized for a week).
- State of Minnesota v. Earl Anthony Fry Minn. Ct. App. 2015
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State of Minnesota v. Earl Anthony Fry
Minn. Ct. App. 2015
(“Arguably, 7 great bodily harm is inflicted if one knocks someone out briefly.” (quotation omitted)); (concluding that sufficient evidence existed to find that the victim suffered great bodily harm when she was found unconscious, on the verge of shock, lost consciousness for a day, was hospitalized for a week, and almost suffered a miscarriage).
- State of Minnesota v. Thomas Jerard Swenson Minn. Ct. App. 2015
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State of Minnesota v. Thomas Jerard Swenson
Minn. Ct. App. 2015
(“Arguably, ‘great bodily harm’ is inflicted if one knocks someone out briefly.”); (concluding that there was sufficient evidence to justify finding that the victim suffered great bodily harm when she was found unconscious and on the verge of shock, did not regain consciousness for a day, was hospitalized for a week, and almost suffered a miscarriage).
- State v. Brooks 838 N.W.2d 563 Minn. 2013
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State v. Brooks
838 N.W.2d 563
Minn. 2013
(holding that defendants’ waiver of their right to counsel was voluntarily made, in part, because they were able to consult with counsel before they made the decision); (finding that waiver of right to counsel was voluntary, because court could presume public defender had described “the benefits of legal assistance and the risks of proceeding without it” to defendant); see also Henderson v. Morgan, 426 U.S. 637, 647 , 96 S.Ct.
- State v. Weyaus 836 N.W.2d 579 Minn. Ct. App. 2013
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State v. Weyaus
836 N.W.2d 579
Minn. Ct. App. 2013
1995) (“A state of unconsciousness verging on shock has been held to satisfy the higher standard of ‘great bodily harm.’ ”) ( (rejecting Jones’s argument that insufficient evidence justified finding that victim suffered great bodily harm when victim was found “unconscious and on the verge of shock,” “did not regain consciousness until the following day,” “remained hospitalized for a week,” about two weeks after the attack al
- State v. Haggins 798 N.W.2d 86 Minn. Ct. App. 2011
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State v. Haggins
798 N.W.2d 86
Minn. Ct. App. 2011
When a defendant has previously been represented by counsel, a district court “[can] reasonably presume that the benefits of legal assistance and the risks of proceeding without it [have] been described to defendant in detail.”
- State v. Jones 772 N.W.2d 496 Minn. 2009
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State v. Jones
772 N.W.2d 496
Minn. 2009
-44 (Minn.2006); Worthy, d at 276
- State v. Jones 755 N.W.2d 341 Minn. Ct. App. 2008
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State v. Jones
755 N.W.2d 341
Minn. Ct. App. 2008
711 n. 1 (Minn.1978) (encouraging district courts to “liberally use the authority provided in” rule 5.02).
- State v. Clark 722 N.W.2d 460 Minn. 2006
- State v. Clark 722 N.W.2d 460 Minn. 2006
- State v. Larkin 620 N.W.2d 335 Minn. Ct. App. 2001
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State v. Larkin
620 N.W.2d 335
Minn. Ct. App. 2001
In State v. Stafford, the supreme court stated, “Arguably, ‘great bodily harm’ is inflicted if one knocks someone out brief *337 ly.” 1 ().
- State v. Worthy 583 N.W.2d 270 Minn. 1998
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State v. Worthy
583 N.W.2d 270
Minn. 1998
When a defendant has consulted with an attorney prior to waiver, a trial court could “reasonably presume that the benefits of legal assistance and the risks of proceeding without it had been described to defendant in detail by counsel.”
- State v. Gorman 532 N.W.2d 229 Minn. Ct. App. 1995
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State v. Gorman
532 N.W.2d 229
Minn. Ct. App. 1995
A state of unconsciousness verging on shock has been held to satisfy the higher standard of “great bodily harm.”
- State v. Barner 510 N.W.2d 202 Minn. 1993
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State v. Barner
510 N.W.2d 202
Minn. 1993
8, defines “great bodily harm” as “bodily injury which creates a high probability of death, or which causes serious permanent disfigurement, or which causes a permanent or protracted loss or impairment of the function of any bodily member or organ or other serious bodily harm.” Relevant decisions of this court include: State v. Peters, 274 Minn. 309
- State v. Krejci 458 N.W.2d 407 Minn. 1990
- State v. Krejci 458 N.W.2d 407 Minn. 1990
- State v. Richards 456 N.W.2d 260 Minn. 1990
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State v. Richards
456 N.W.2d 260
Minn. 1990
E.g., State v. Bauer, 310 Minn. 103, 122-26 , -61 (1976) (adopting ABA Standards); -12 (1978).