Cited by
Opinions in Minnesota that cite State v. Eaton, 292 N.W.2d 260.
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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
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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).
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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).
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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
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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).
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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
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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
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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 ).
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State of Minnesota, Respondent,
Minn. Ct. App. 2018
d 260, 267 (Minn. 1980) (holding that a “plan to swindle as much as possible.
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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
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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
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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
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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
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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
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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
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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
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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
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State v. Soto
562 N.W.2d 299
Minn. 1997
(citation omitted); (citation omitted).
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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
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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
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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
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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