Cited by

Opinions in Minnesota that cite State v. Eaton, 292 N.W.2d 260.

75 citing documents.

State of Minnesota, Respondent, Minn. Ct. App. 2025
n.5 (comparing Langdon, d at 476, -67 (Minn. 1980)).
State of Minnesota, Respondent, Minn. Ct. App. 2025
State of Minnesota, Respondent, Minn. Ct. App. 2024
Appellant also notes that courts have rejected broad criminal objectives such as “abusive behavior” that might cover both counts 1-4 and counts 5-6, -67 (Minn. 1980) rev. denied (Minn. May 24, 1989).
State of Minnesota, Respondent, Minn. Ct. App. 2024
“A single behavioral incident is the result of a single motivation directed towards a single criminal goal.” State v. Infante , (), rev. denied (Minn. June 28, 2011); (where the defendant’s actions in obstructing-legal-process case were part of a “single behavioral incident,” jury was not required to unanimously agree on his specific actions).
State of Minnesota, Respondent, Minn. Ct. App. 2024
Minnesota Statutes section 609.251 (2020) provides: “a prosecution for or conviction of the crime of kidnapping is not a bar to conviction of or punishment for any other crime committed during the time of the kidnapping.” A
State of Minnesota, Respondent, Minn. Ct. App. 2024
One way in which a prosecutor may deprive a defendant of a fair trial is by “mak[ing] insinuations on cross-examination that the prosecutor cannot back up with admissible evidence.” -97 (Minn. 1979).
State of Minnesota, Respondent, Minn. Ct. App. 2022
at occurred over a short time period, for the purpose of a “single criminal goal,” were a single behavioral incident); see, e.g., Dalbec, d at 512-13 (holding that no specific-unanimity instruction was required when a defendant committed multiple acts of domestic assault “at the same place” involving “a single victim,” even though the acts occurred over 24 hours); d 260, 267 (Minn. 1980) (holding that appellant’s objective of “one large plan to swindle as much as possible” was too broad to be a
State of Minnesota, Respondent, Minn. Ct. App. 2020
“Making deceptive billings a continuing business practice does not transform them into a single behavioral incident.” Id.; see also, (stating that “one large plan to swindle as much as possible” is “too broad to be a single criminal goal”); State v. O’Brien, (affirming use of Hernandez method for each of four counts of theft by swindle arising out of the same ongoing fraudulent investment s
State of Minnesota, Respondent, Minn. Ct. App. 2020
21, 1986); (concluding no unity of time and place where the state charged defendant with theft of two different checks at two different 12 times three days apart ).
State of Minnesota, Respondent, Minn. Ct. App. 2018
d 260, 267 (Minn. 1980) (holding that a “plan to swindle as much as possible.
State of Minnesota, Respondent, Minn. Ct. App. 2018
Compare Langdon , d at 476 (concluding that four burglaries of an apartment complex on the same afternoon were committed with a single “overall criminal objective”), with State v. Eaton , d 260, 266 -67 (Minn. 1980) ( concluding that two thefts, committed three days apart by swindling the same victims, were not committed with a single criminal objective).
State of Minnesota v. Timothy John Bakken 883 N.W.2d 264 Minn. 2016
State of Minnesota v. Timothy John Bakken 883 N.W.2d 264 Minn. 2016
within the meaning of section 609.035”); -67 (Minn. 1980) (explaining that when appellant was convicted of two counts of theft by swindle for acts occurring 3 days apart, the objective of “swindl[ing] as much as possible” was “too broad to be a single criminal goal”).
State of Minnesota v. Timothy John Bakken 871 N.W.2d 418 Minn. Ct. App. 2015
State of Minnesota v. Timothy John Bakken 871 N.W.2d 418 Minn. Ct. App. 2015
Appellant’s actions here are comparable.
Eduardo Cortez, Jr. v. State of Minnesota Minn. Ct. App. 2015
Eduardo Cortez, Jr. v. State of Minnesota Minn. Ct. App. 2015
State of Minnesota v. Don Antoine Jones 848 N.W.2d 528 Minn. 2014
State of Minnesota v. Don Antoine Jones 848 N.W.2d 528 Minn. 2014
State v. Infante 796 N.W.2d 349 Minn. Ct. App. 2011
State v. Infante 796 N.W.2d 349 Minn. Ct. App. 2011
“[A] single behavioral incident is the result of a single motivation directed towards a single criminal goal.”
State v. Bauer 792 N.W.2d 825 Minn. 2011
State v. Bauer 792 N.W.2d 825 Minn. 2011
Our case law recognizes that “the criminal plan of obtaining as much money as possible is too broad an objective to constitute a single criminal goal within the meaning of section 609.035.” Gould, d at 521 (-67 (Minn.1980)).
State v. Heath 685 N.W.2d 48 Minn. Ct. App. 2004
State v. Heath 685 N.W.2d 48 Minn. Ct. App. 2004
The statute is intended “to protect against exaggerating the criminality of a person’s conduct and to make both punishment and prosecution commensurate with culpability.” () (other citation omitted), review denied (Minn. May 24, 1989).
State v. Marchbanks 632 N.W.2d 725 Minn. Ct. App. 2001
State v. Marchbanks 632 N.W.2d 725 Minn. Ct. App. 2001
(noting single behavioral incident is result of single motivation directed toward single criminal goal).
State v. Craven 628 N.W.2d 632 Minn. Ct. App. 2001
State v. Craven 628 N.W.2d 632 Minn. Ct. App. 2001
In Re Estate of Janecek 610 N.W.2d 638 Minn. 2000
In Re Estate of Janecek 610 N.W.2d 638 Minn. 2000
State v. Greenleaf 591 N.W.2d 488 Minn. 1999
State v. Greenleaf 591 N.W.2d 488 Minn. 1999
State v. Lundberg 575 N.W.2d 589 Minn. Ct. App. 1998
State v. Lundberg 575 N.W.2d 589 Minn. Ct. App. 1998
1 (1996) (providing if defendant’s conduct constitutes more than one offense, he may be punished for only one of the offenses); (concluding purpose of Minn.Stat.
State v. Gould 562 N.W.2d 518 Minn. 1997
State v. Soto 562 N.W.2d 299 Minn. 1997
State v. Soto 562 N.W.2d 299 Minn. 1997
(citation omitted); (citation omitted).
State v. Gould 562 N.W.2d 518 Minn. 1997
3 (citation omitted); (citation omitted).
State v. Townsend 546 N.W.2d 292 Minn. 1996
State v. Townsend 546 N.W.2d 292 Minn. 1996
State v. Fallin 540 N.W.2d 518 Minn. 1995
State v. Fallin 540 N.W.2d 518 Minn. 1995
State v. Pittel 518 N.W.2d 606 Minn. 1994
State v. Pittel 518 N.W.2d 606 Minn. 1994
Among the many relevant cases, (upholding two convictions and two sentences where the defendant, as part of a single scheme to cheat a victim, obtained $12,500 on one date and $30,000 on another date; while it was true that the defendant “had one large plan to swindle as much as possible” from the victim, “that objective is too bro
State v. Medibus-Helpmobile, Inc. 481 N.W.2d 86 Minn. Ct. App. 1992
State v. Medibus-Helpmobile, Inc. 481 N.W.2d 86 Minn. Ct. App. 1992
(eight forgeries by employee over four-year period were not a single behavioral incident); (swindle).
State v. O'HAGAN 474 N.W.2d 613 Minn. Ct. App. 1991
State v. O'HAGAN 474 N.W.2d 613 Minn. Ct. App. 1991
(“one large plan to swindle as much as possible * * * [was] too broad to be a single criminal goal within the meaning of section 609.035 where defendant planned and executed thefts of two different checks at two separate times” only three days *623 apart).
State v. Lamar 474 N.W.2d 1 Minn. Ct. App. 1991