Cited by
Opinions in Minnesota that cite State v. Lindsey, 284 N.W.2d 368.
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State of Minnesota, Respondent,
Minn. Ct. App. 2026
When deciding the appropriate remedy, the district court must assess whether the discovery violation harmed the defendant and “the extent to which th[e] harm can be eliminated or otherwise alleviated.”
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State of Minnesota, Respondent,
Minn. Ct. App. 2026
(providing four factors for district courts to consider when imposing sanctions for discovery violations).
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State of Minnesota, Respondent,
Minn. Ct. App. 2026
(discovery violation); (relationship evidence).
- State of Minnesota, Respondent, Minn. Ct. App. 2026
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State of Minnesota, Respondent,
Minn. Ct. App. 2025
In determining the appropriate remedy, a district court “should take into account: (1) the reason why disclosure was not made; (2) the extent of prejudice to the opposing party; (3) the feasibility of rectifying that prejudice by a continuance; and (4) any other relevant factors.” d 537, 547 (Minn. 2023) ().
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State of Minnesota, Respondent,
Minn. Ct. App. 2025
Precluding evidence because of a discovery violation is a “severe sanction which should not be lightly invoked.”
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Juan Silva, petitioner, Appellant,
Minn. Ct. App. 2025
Silva contended that the actual date of conviction was in November 2000, and that, “[a]fter being apprised 2
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State of Minnesota, Respondent,
Minn. Ct. App. 2025
“Pretrial discovery rules fulfill an essential role in the criminal justice system.”
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State of Minnesota, Respondent,
Minn. Ct. App. 2025
State v. 7 Lindsey, (stating that appellate courts review sanctions for an abuse of discretion).
- State of Minnesota v. Nicholas Norton Engel Minn. Ct. App. 2025
- State of Minnesota v. Nicholas Norton Engel Minn. Ct. App. 2025
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State of Minnesota, Respondent,
Minn. Ct. App. 2025
In determining the appropriate remedy, a district court “should take into account: (1) the reason why disclosure was not made; (2) the extent of prejudice to the opposing party; 6 (3) the feasibility of rectifying that prejudice by a continuance; and (4) any other relevant factors.”
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State of Minnesota, Appellant,
Minn. Ct. App. 2025
(stating that district courts should consider “(1) the reason why disclosure was not made; (2) the extent of prejudice to the opposing party; (3) the feasibility of rectifying that prejudice by a continuance; and (4) any other relevant factors”).
- State of Minnesota, Respondent, Minn. Ct. App. 2025
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State of Minnesota, Appellant,
Minn. Ct. App. 2024
However, because the dissent reaches the merits of the pretrial order, we elect to address it here and conclude that, the district court did not abuse its discretion by precluding the state from using DNA evidence “that they failed to collect by the deadline of December 1, 2023,” as a sanction.
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State of Minnesota, Respondent,
Minn. Ct. App. 2024
In ruling on a motion for a mistrial based on a discovery violation, the district court should consider “(1) the reason why disclosure was not made; (2) the extent of prejudice to the opposing party; (3) the feasibility of rectifying that prejudice by a co ntinuance; and (4) any other relevant factors.”
- State of Minnesota v. Jerry Arnold Westrom 6 N.W.3d 145 Minn. 2024
- State of Minnesota v. Jerry Arnold Westrom 6 N.W.3d 145 Minn. 2024
- Jason Lamar Forest v. State of Minnesota Minn. Ct. App. 2024
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Jason Lamar Forest v. State of Minnesota
Minn. Ct. App. 2024
But that right does not absolve a defendant of his duty to comply with procedural rules in order to maintain “[t]he values sought to be achieved through reciprocal discovery.” -74 (Minn. 1979).
- Dakota County Anderson, J. ConState of Minnesota v. Gabriel Alfonso Sanchez Cruz Minn. 2023
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Dakota County Anderson, J. ConState of Minnesota v. Gabriel Alfonso Sanchez Cruz
Minn. 2023
In formulating its remedy, the district court “should take into account: (1) the reason why disclosure was not made; (2) the extent 12 of prejudice to the opposing party; (3) the feasibility of rectifying that prejudice by a continuance; and (4) any other relevant factors.”
- State of Minnesota v. Ryan James Martens Minn. Ct. App. 2023
- State of Minnesota v. Ryan James Martens Minn. Ct. App. 2023
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State of Minnesota, Respondent,
Minn. Ct. App. 2023
(d 368, 373 (Minn. 1979)).
- State of Minnesota, Respondent, Minn. Ct. App. 2023
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State of Minnesota, Respondent,
Minn. Ct. App. 2023
“The imposition of sanctions for violations of discovery rules and orders is a matter particularly suited to the judgment and discretion of the trial court.”
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State of Minnesota, Respondent,
Minn. Ct. App. 2022
If a defendant fails to give the requisite notice, the district court “is in the best position to determine whether any harm has resulted from the [discovery] violation and the extent to which this harm can be eliminated or otherwise alleviated.”
- State of Minnesota, Respondent, Minn. Ct. App. 2022
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State of Minnesota, Respondent,
Minn. Ct. App. 2021
“The imposition of sanctions for violations of discovery rules and orders is a matter particularly suited to the judgment a nd discretion of the trial court.”
- State of Minnesota, Respondent, Minn. Ct. App. 2021
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State of Minnesota, Respondent,
Minn. Ct. App. 2020
The imposition of sanctions for a discovery violation “is a matter particularly suited to the judgment and discretion of the trial court.”
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State of Minnesota, Respondent,
Minn. Ct. App. 2020
State v. Palubicki, 7 -90 (Minn. 2005); -98 (Minn. 1995); -74 (Minn. 1979).
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State of Minnesota, Respondent,
Minn. Ct. App. 2020
Imposing sanctions for a discovery violation “is a matter particularly suited to the judgment and discretion of the [district] court.”
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State of Minnesota, Respondent,
Minn. Ct. App. 2020
“The imposition of sanctions for violations of discovery rules and orders is a matter particularly suited to the judgment and discretion of the [district] court.” .
- State of Minnesota, Respondent, Minn. Ct. App. 2019
- State of Minnesota, Respondent, Minn. Ct. App. 2019
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State of Minnesota, Respondent,
Minn. Ct. App. 2019
missible, the court still had discretion to exclude them because the defense unjustifiably failed to disclose [the] posts until after the State’s eyewitnesses had testified.” 11 The state relies on State v. Lindsey, in which the supreme court held, “The imposition of sanctions for violations of discovery rules is a matter for the sound judgment and discretion of the [district] court.”
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State of Minnesota, Respondent,
Minn. Ct. App. 2018
To determine whether the decision to permit expert testimony despite the dis covery violation was an abuse of discretion
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State of Minnesota, Respondent,
Minn. Ct. App. 2018
“The imposition of sanctions for violations of discovery rules and orders is a matter particularly suited to the judgment and discretion of the [district] court.” State v. Lindsey, 18
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State of Minnesota, Respondent,
Minn. Ct. App. 2018
But he stated he was ready “to go ahead with trial” because “r ealistically almost a ll of this information that’s in [his] exhibit list” could be produced “from [the state’s] witnesses.” The district court excluded all of appellant’s late disclosures after determining that exclusion was the proper discovery sanction under State v. Lindsey
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State of Minnesota, Respondent,
Minn. Ct. App. 2018
1, and in doing so, the district court should take into account “(1) the reason why disclosure was not made; (2) the extent of prejudice to the opposing party; (3) the feasibility of rectifying that prejudice by a continuance; and (4) any other relevant factors.”
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State of Minnesota, Respondent,
Minn. Ct. App. 2018
14 In determining whether to impose sanctions for a discovery violation , the district court considers “(1) the reason why disclosure was not made; (2) the extent of prejudice to the opposing party; (3) the feasibility of rectifying that prejudice by a continuance; and (4) any other relevant factors.”
- State of Minnesota, Respondent, Minn. Ct. App. 2017
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State of Minnesota, Respondent,
Minn. Ct. App. 2017
.3 Without discussing the Lindsey factors, the district court concluded the state would be prejudiced if 3 The four factors are: “(1) the reason why disclosure was not made; (2) the extent of prejudice to the opposing party; (3) the feasibility of r
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State of Minnesota, Respondent,
Minn. Ct. App. 2017
When considering sanctions for discovery violations, the district court should “take into account: (1) the reason why disclosure was not made; (2) the extent of prejudice to the opposing party; (3) the feasibility of rectifying that prejudice by a continuance; and (4) any other relevant factors.”
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State of Minnesota, Respondent,
Minn. Ct. App. 2017
When considering a sanction for a discovery violation, the district court should “take into account: (1) the reason why disclosure was not made; (2) the extent of prejudice to the opposing party; (3) the feasibility of rectifying that prejudice by a continuance; and (4) any other relevant factors.”
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State of Minnesota, Respondent,
Minn. Ct. App. 2017
District courts should consider the four “Lindsey” factors when determining discovery sanctions: “(1) the reason why disclosure was not made; (2) the extent of prejudice to the opposing party; (3) the feasibility of rectifying that prejudice by a continuance; and (4) any other relevant factors.”
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State of Minnesota, Respondent,
Minn. Ct. App. 2017
“[F]or discovery to achieve its intended purposes the rules must be complied with, and this requires that adequate sanctions exist for their enforcement.” .
- State of Minnesota v. Edwin Albert Dlugopolski Minn. Ct. App. 2016