Cited by
Opinions in Minnesota that cite State v. Wiberg, 296 N.W.2d 388.
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State of Minnesota, Respondent,
Minn. Ct. App. 2021
See State v. Wiberg , (“An informant’s reliability on a particular occasion can also be established if the statements of the informant can be at least partially corroborated independently.”).
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State of Minnesota, Respondent,
Minn. Ct. App. 2018
See State v. Wiberg , (citing favorably to Husten v. United States, 95 F.2d 168, 170 (8th Cir. 1938), which held that unexplained possession of recently stolen property is sufficient to support a jury finding that defendant knew it was stolen).
- State of Minnesota v. Christopher Davis Schultz Minn. Ct. App. 2017
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State of Minnesota v. Christopher Davis Schultz
Minn. Ct. App. 2017
Statements against interest enhance reliability because “‘[p]eople do not lightly admit a crime and place critical evidence in the hands of the police in the form of their own admissions.’” & n.7 (Minn. 1980) (quoting United States v. Harris, 403 U.S. 573, 583, 91 S. Ct. 2075, 2082 (1971)).
- State of Minnesota, Respondent/Cross-Appellant v. Bonnie Ann Lindquist, Appellant/Cross-Respondent. 869 N.W.2d 863 Minn. 2015
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State of Minnesota, Respondent/Cross-Appellant v. Bonnie Ann Lindquist, Appellant/Cross-Respondent.
869 N.W.2d 863
Minn. 2015
Next, -93 (Minn.1980), we addressed whether a defendant’s statement made 2 days after her arrest should be suppressed because of a violation of Minn. R.Crim.
- State of Minnesota v. Zephaniah James Skarja Minn. Ct. App. 2014
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State of Minnesota v. Zephaniah James Skarja
Minn. Ct. App. 2014
“[A]n informant’s reliability on a particular occasion can be established by a declaration by the informant that is against his penal interest.”
- Johnson v. State 673 N.W.2d 144 Minn. 2004
- Johnson v. State 673 N.W.2d 144 Minn. 2004
- State v. Waddell 655 N.W.2d 803 Minn. 2003
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State v. Waddell
655 N.W.2d 803
Minn. 2003
we noted that the rationale of such a rule is to: [Ajvoid the coercive nature of custodial surroundings by preventing secret interrogation and the resultant pressure to confess.
- State v. Ward 580 N.W.2d 67 Minn. Ct. App. 1998
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State v. Ward
580 N.W.2d 67
Minn. Ct. App. 1998
The rationale for the credit given to statements against interest is that “[people do not lightly admit a crime and place critical evidence in the hands of the police in the form of their own admissions.” , 395 n. 7 (Minn.1980) (quoting United States v. Harris, 403 U.S. 573, 583 , 91 S.Ct.
- In Re the Welfare of M.E.P. 523 N.W.2d 913 Minn. Ct. App. 1994
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In Re the Welfare of M.E.P.
523 N.W.2d 913
Minn. Ct. App. 1994
(rejecting rule of automatic suppression); (following Wiberg), aff'd (addressing separate issue).
- State v. Jackson 472 N.W.2d 861 Minn. 1991
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State v. Jackson
472 N.W.2d 861
Minn. 1991
The court of appeals reached the same conclusion but, 1 concluded that suppression was not required.
- State v. Jackson 469 N.W.2d 457 Minn. Ct. App. 1991
- State v. Jackson 469 N.W.2d 457 Minn. Ct. App. 1991
- Costillo v. Commissioner of Public Safety 416 N.W.2d 730 Minn. 1987
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Costillo v. Commissioner of Public Safety
416 N.W.2d 730
Minn. 1987
however, (refusing to automatically exclude confession obtained from Spanish-speaking defendant in violation of statute requiring appointment of interpreter); (questioning whether exclusionary rule should apply to any violation of state law by officer in acting outside his jurisdiction); (refusing to automatically exclude statement obtained as a product of unnecessary delay before arraignment under our state rules of criminal procedure); (holding that nighttime execution of search warrant was a
- State v. Case 412 N.W.2d 1 Minn. Ct. App. 1987
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State v. Case
412 N.W.2d 1
Minn. Ct. App. 1987
Although delays for more than 36 hours are presumptively illegal, and evidence obtained as a result of such a delay can be excluded by the trial court, -47 (Minn.1982), the police obtained no evidence which was used against Case at trial.
- State v. Anderson 405 N.W.2d 527 Minn. Ct. App. 1987
- State v. Anderson 405 N.W.2d 527 Minn. Ct. App. 1987
- State v. Reynolds 386 N.W.2d 828 Minn. Ct. App. 1986
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State v. Reynolds
386 N.W.2d 828
Minn. Ct. App. 1986
appellant’s argument falls: [Wjhen a defendant requests the trial court not to instruct the jury on a lesser included offense and the trial judge honors defendant’s request, the defendant is precluded from raising the issue on appeal.
- State v. True 378 N.W.2d 45 Minn. Ct. App. 1985
- State v. True 378 N.W.2d 45 Minn. Ct. App. 1985
- State v. Peterson 375 N.W.2d 93 Minn. Ct. App. 1985
- State v. Peterson 375 N.W.2d 93 Minn. Ct. App. 1985
- State v. Dye 371 N.W.2d 47 Minn. Ct. App. 1985
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State v. Dye
371 N.W.2d 47
Minn. Ct. App. 1985
Rather, “the trial court should consider, among other things, how reliable the evidence is, whether the delay was intentional, whether the delay compounded the *52 effects of other police misconduct, and the length of the delay.”
- State v. L'ITALIEN 363 N.W.2d 490 Minn. Ct. App. 1985
- State v. L'ITALIEN 363 N.W.2d 490 Minn. Ct. App. 1985
- State v. Banks 358 N.W.2d 133 Minn. Ct. App. 1984
- State v. Banks 358 N.W.2d 133 Minn. Ct. App. 1984
- State v. Patricelli 357 N.W.2d 89 Minn. 1984
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State v. Patricelli
357 N.W.2d 89
Minn. 1984
Cases of this court discussing whether a second confession or statement was the fruit of an earlier, State v. Raymond, 305 Minn. 160
- State v. Propotnik 355 N.W.2d 195 Minn. Ct. App. 1984
- State v. Propotnik 355 N.W.2d 195 Minn. Ct. App. 1984
- State v. Wiley 348 N.W.2d 86 Minn. Ct. App. 1984
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State v. Wiley
348 N.W.2d 86
Minn. Ct. App. 1984
Finally, a reading of the application for the warrant reflects that the reliability of the CRI was “at least partially corroborated independently” on the particular occasion involved by the officer seeking the warrant, and is an additional reason for sustaining the magistrate.
- State v. Odenbrett 349 N.W.2d 265 Minn. 1984
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State v. Odenbrett
349 N.W.2d 265
Minn. 1984
1654 (1947); -94 (Minn.1980); State v. Raymond, 305 Minn. 160, 168-71 , -85 (1975).
- State v. Pierce 347 N.W.2d 829 Minn. Ct. App. 1984
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State v. Pierce
347 N.W.2d 829
Minn. Ct. App. 1984
our Supreme Court found a violation of the prompt arraignment rule, even though 36 hours had not yet elapsed (exclusive of the day of arrest).
- Hanson v. State 344 N.W.2d 420 Minn. Ct. App. 1984
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Hanson v. State
344 N.W.2d 420
Minn. Ct. App. 1984
Also, “an informant’s reliability on a particular occasion can be established by a declaration by the informant that is against his penal interest.” (citing United States v. Harris, 403 U.S. 573 , 91 S.Ct.