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The admission of inadmissible evidence is not reversible error if the prosecutor did not intentionally elicit the testimony, the statement at issue was merely a “passing” reference, and the evidence supporting guilt was “overwhelming.”

See, (declining to reverse an aggravated-robbery conviction in part because the State’s evidence was overwhelming based on “positive testimony” and “strong corroborating evidence,” including testimony about physical evidence); (concluding that the State

ver, the unintentional admission of inadmissible evidence is not reversible error 2 We note that appellant’s trial counsel stated that he “[did]n’t think that the county attorney failed to prepare their witnesses.” 9 if the statement was merely a “passing” reference, and the evidence against the defendant was “overwhelming.” -06 (Minn. 1978).

State v. Dunkel , ( d 87, 92 (Minn. 1971 )).

-06 (Minn. 11 1978) (stating that the admission of inadmissible and prejudicial evidence is not reversible error if the prosecutor did not intentionally elicit the testimony, the statement was merely a passing reference, and the evidence of guilt was strong).

But the admission of inadmissible and prejudicial evidence is not reversible error if the prosecutor did not intentionally elicit the testimony, the statement at issue was merely a “passing” reference, and the evidence supporting guilt was “overwhelming.”

But the ad mission of inadmissible and prejudicial evidence is not reversible error if the prosecutor did not intentionally elicit the testimony, the statement at issue was merely a “passing” reference, and the evidence supporting guilt was “overwhelming.” -06 (Minn. 1978).

(discussing the idea that a specific curative instruction would emphasize an i nadvertent prejudicial reference).

“[I]f the prosecutor inte ntionally elicits other-crime evidence knowing that it is inadmissible, we will reverse more readily.”

But the admission of inadmissible and prejudicial evidence is not reversible error if the prosecutor did not intentionally elicit the testimony, the statement at issue was merely a “passing” reference, and the evidence supporting guilt was “overwhelming.” -06 (Minn. 1978).

d 166, 170 (Minn. App. 1992) ().

(finding that a witness’s testimony that a defendant had previously been incarcerated was not reversible error because the testimony was not intentionally elicited, the statement was “of a passing nature,” and the evidence in [the] case was overwhelming”).

8 But the admission of such evidence is not reversible error if the state did not intentionally elicit the testimony, the statement was merely a “passing” reference, and the evidence supporting guilt was “overwhelming.”

(affirming where reference to past incarceration “was of a passing nature” and the evidence of guilt was overwhelming); Richmond, 298 Minn. at 562-63, d at 695-96 (considering testimony that a “2-year-old photograph [was] ‘taken at the LaCrosse Police Department’” and affirming because t

(“[E]ven when the elicitation is unintentional, we will reverse if the evidence is prejudicial.”).

(discussing the idea that a specific curative instruction would emphasize an inadvertent prejudicial reference).

Where, as here, a reference to a defendant’s prior record is of a “passing nature,” or the evidence of guilt is “overwhelming,” a new trial is not warranted because it is extremely unlikely “that the evidence in question played a significant role in persuading the jury to convict.”

(testimony of a passing nature regarding other trouble with the law not prejudicial when overwhelming evidence of guilt present); (relying on Haglund , this court found inadvertent reference to other crimes not prejudicial).