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Cited by

Opinions in Minnesota that cite State v. Waukazo, 269 N.W.2d 373.

35 citing documents.

  • State of Minnesota, Respondent, Minn. Ct. App. 2024
  • State of Minnesota, Minn. 2021
    9 v. Waukazo, (“[A]n indictment or complaint should be as specific as possible with respect to time.
  • State of Minnesota, Respondent, Minn. Ct. App. 2019
    And, in general, “it is not always possible to know with certainty” when an offense 9 occurred, especially “where there is a minor victim who does not complain to the authorities immediately.”
  • State of Minnesota v. Rocky Lane Zahrowski Minn. Ct. App. 2015
  • State of Minnesota v. Rocky Lane Zahrowski Minn. Ct. App. 2015
    Zahrowski’s argument fails, however, because section 609.341, subdivision 10 does not require one parent to explicitly communicate their expectations to establish a “position of authority.” –76 (Minn. 1978) (upholding first-degree criminal- sexual-conduct conviction despite lack of express duty or authority to care for the child).
  • Winhaven Court Apartments v. Sally Carney Minn. Ct. App. 2015
  • Winhaven Court Apartments v. Sally Carney Minn. Ct. App. 2015
    the criminal context, courts have stated that a complaint must inform a defendant of the “nature and cause of the accusation” by “contain[ing] such descriptions of the offense charged as will enable him to make his defense” and “to protect him from subsequent prosecution for the same offense.” -30 (Minn. 2006) (quotations omitted); (stating that the allegations against the defendant must not be “so vague under the circumstances as to make it impossible for a defendant to prepare his defense”).
  • Ruberg v. State 428 N.W.2d 488 Minn. Ct. App. 1988
  • Ruberg v. State 428 N.W.2d 488 Minn. Ct. App. 1988
    The general rule is codified in § 628.15 * * * * Becker, d at 926 ().
  • State v. Willette 421 N.W.2d 342 Minn. Ct. App. 1988
  • State v. Willette 421 N.W.2d 342 Minn. Ct. App. 1988
    .1987) (evidence that complainant babysat for defendant and that he had threatened her was sufficient to support finding of “position of authority”); (evidence that complainant was occasionally left in defendant uncle’s care and that he threatened her with “trouble” if she refused sufficed to support finding of position of authority); State v. Waukazo, *346 (adult son of complainant’s foster parents was in a position of authority over complainant).
  • State v. Bias 419 N.W.2d 480 Minn. 1988
  • State v. Bias 419 N.W.2d 480 Minn. 1988
  • State v. Warborg 395 N.W.2d 368 Minn. Ct. App. 1986
  • State v. Warborg 395 N.W.2d 368 Minn. Ct. App. 1986
  • State v. Scheu 392 N.W.2d 640 Minn. Ct. App. 1986
  • State v. Scheu 392 N.W.2d 640 Minn. Ct. App. 1986
  • State v. Rud 359 N.W.2d 573 Minn. 1984
  • State v. Rud 359 N.W.2d 573 Minn. 1984
    which is the leading case on the subject.
  • State v. Eggert 358 N.W.2d 156 Minn. Ct. App. 1984
  • State v. Eggert 358 N.W.2d 156 Minn. Ct. App. 1984
    merely holds that there are cases in which the court may require more specificity of the complaint in order to allow the defendant to prepare a defense.
  • State v. Fader 358 N.W.2d 42 Minn. 1984
  • State v. Fader 358 N.W.2d 42 Minn. 1984
  • State v. Jannetta 355 N.W.2d 189 Minn. Ct. App. 1984
  • State v. Jannetta 355 N.W.2d 189 Minn. Ct. App. 1984
  • State v. Becker 351 N.W.2d 923 Minn. 1984
  • State v. Becker 351 N.W.2d 923 Minn. 1984
    Regarding the specificity of the time element of the offense, : We also think it is clear that, as a general proposition, an indictment or complaint should be as specific as possible with respect to time.
  • State v. Stagg 342 N.W.2d 124 Minn. 1984
  • State v. Stagg 342 N.W.2d 124 Minn. 1984
    However, : Notwithstanding the general rule, there might be cases in which the allegations as to time in the indictment or complaint would be so vague under the circumstances as to make it impossible for a defendant to prepare his defense.
  • State v. Harding 304 N.W.2d 14 Minn. 1981
  • State v. Harding 304 N.W.2d 14 Minn. 1981
  • State v. Lehman 295 N.W.2d 264 Minn. 1980
  • State v. Lehman 295 N.W.2d 264 Minn. 1980
    While “this court always has authority to reverse a conviction if it believes that the charge was so vague on the matter of time as to make it impossible for the defendant to defend himself,” — — the defendant in this case has not made such a showing.
  • State v. Bird 292 N.W.2d 3 Minn. 1980
  • State v. Bird 292 N.W.2d 3 Minn. 1980
    we upheld a conviction under this section where the evidence established thaan adult son of the complainant’s foster parents had a position of authority over the complainant and used this authority to coerce the complainant to submit to sexual penetration.