Cited by

The first, State v. Black, states: “The right of confrontation is a fundamental right under both constitutions.” d 208, 213 (Minn. 1980).

–31, 834 (Minn. 1998); (upholding the admission of Spreigl evidence to show that the defendant’s motive to commit murder was to silence a witness to outstanding robbery charges against the defendant).

at 682, 687 (Spreigl evidence of defendant’s prior sexual misconduct was not admissible to show motive in prosecution for criminal sexual misconduct) , with State v. Black , d 208, 215 (Minn. 1980) (upholding admission of Spreigl evidence to show that motive for murder was to silence witness on outstanding robbery charges a gainst defendant) , n.4 (Minn. 1996).

(affirming the district court’s finding that the defendant forfeited his right to confront the victim when she refused to testify because he intimidated her into silence), n.4 (Minn. 1996).

See, -86 (Minn.2001); , 909 n. 4 (Minn.1996); see also Ideal Life Church of Lake Elmo, d at 315 (approving the use of a multifaceted test to determine whether an institution is a “church” for tax purposes).

(noting that the prosecution called recalcitrant witness who lacked a valid privilege to “determine with certainty” whether she would testify and to lay a foundation for admitting her prior statements and testimony).

("The law is clear that if a witness is unavailable because of the wrongdoing of the defendant, the defendant cannot complain if other competent evidence is introduced to take the place of the witness’[s] testimony.”).

(holding that request from inmate to county jail chaplain to pass information to co-eonspir- *84 ator was not privileged because the aid requested was not religious and because the request was not intended to be confidential).

See also, (upholding admission of Spreigl evidence to show that motive for murder was to silence witness on outstanding robbery charges against defendant); (allowing Spreigl evidence to show that gang affiliation was motive for murder).

244 (1878); (defendant forfeited his confrontation rights by intimidating the witness into silence).

See, (basing determination that communication was not protected by clergy privilege in part on finding that content of communication was not religious); (basing determination that clergy privilege did not apply on finding that content of communication was not religious); (basing determination that clergy privilege did apply on application of three factual criteria to find that conversations between de

killing her); (allowing evidence of' defendant’s prior attempt to poison the victim to show the strained relationship between the victim and defendant and motive and intent for murder); (admitting testimony of defendant’s threats against the victim’s friends to show motive and intent); (allowing evidence of other robberies involving defendant to show relationship between the victim and defendant as motive for murder), , 909 n. 4 (Minn.1996).

(quoting United States v. Carlson, 547 F.2d 1346, 1359 (8th Cir.1976), cert.

1065, 1067 , 13 L.Ed.2d 923 (1965)

(implicit requirement of clergy privilege is that communications were made with expectation that they would be confidential).

(prior threat admissible to show strained relationship); -15 (Minn.1980) (prior robberies admissible to show relationship between defendant and victims).

While conversations with, or requests for help from, a religious minister are not per-se efforts to obtain spiritual help, (defendant’s request of jail minister to call defendant’s friend and tell her to “go ahead and carry out their plans” did not qualify as a request for spiritual aid), these clergy were called to aid a family in crisis.

(holding that defendant, who intimidated a witness into silence, forfeited his right to confront the witness at trial).

39 , 17 L.Ed.2d 56 (1966); Minn.R.Evid.