Cited by
Opinions in Minnesota that cite State v. Helterbridle, 301 N.W.2d 545.
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State of Minnesota v. Steven Allen Hart
Minn. Ct. App. 2025
We have said that an expert opinion will not assist the trier of fact when “[T]he subject of the testimony is within the knowledge and experience of a lay jury and the testimony of the expert will not add precision or depth to the jury’s ability to reach conclusions about that subject which is within [the jury’s] experience.”
- State of Minnesota v. Brenda Marie Tucker (A22-0966), and Brenda Marie Tucker (A22-0979), vs. State of Minnesota Minn. Ct. App. 2023
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State of Minnesota v. Derek Michael Chauvin
Minn. Ct. App. 2023
702, and whether the subject “is within the knowledge and experience of a lay jury,” State v. Helterbridle
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State of Minnesota v. Anthony Robinson
Minn. Ct. App. 2023
702, and whether the subject “is within the knowledge and experience of a lay jury,”
- State of Minnesota v. Pierre Jerel Anderson Minn. Ct. App. 2022
- State of Minnesota v. Hassan Abdi Minn. Ct. App. 2022
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State of Minnesota v. Justin Raymon Wainner
Minn. Ct. App. 2021
Expert testimony is not helpful if it “is within the knowledge and experience of a lay jury” and “will not add precision or depth to the jury’s ability to reach conclusions about that subject which is within their experience.” see also Jackson, d at 691 (stating that expert opinion testimony on gang behavior “must add precision or depth to the jury’s ability to reach conclusions about matters that are not within its experience”).
- State of Minnesota v. Linden Gene McKinney Minn. Ct. App. 2021
- State of Minnesota v. Wilber Vladimir Gonzalez Romero Minn. Ct. App. 2020
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State of Minnesota v. Yamieyefa Goldpin Ekiyor
Minn. Ct. App. 2020
will not add precision or depth to the jury’s ability to reach conclusions.”
- Michael Thomas Palke v. Commissioner of Public Safety Minn. Ct. App. 2020
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State of Minnesota (A17-1993) (A17-1995) v. Deandre Martell Weaver (A17-1993) (A17-1995)
Minn. Ct. App. 2018
“The basic requirement of Rule 702 is the helpfulness requirement.”
- State of Minnesota v. Jennifer Susan Kline Minn. Ct. App. 2018
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State of Minnesota v. Ronald Dean Smaller
Minn. Ct. App. 2018
d 545, 547 (Minn. 1980).
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State of Minnesota v. Autumn Blakey
Minn. Ct. App. 2018
In determining whether testimony is helpful, courts determine whether the testimony will “add precision or depth to the jury’s ability to reach conclusions.”
- State of Minnesota v. Michael Bryce Martin Minn. Ct. App. 2017
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State of Minnesota v. Israel Davis
Minn. Ct. App. 2017
Expert testimony fails the helpfulness test if it “is within the knowledge and experience of a lay jury and the testimony of the expert will not add precision or depth to the jury’s ability to reach conclusions about that subject which is within their experience.”
- State v. Harris 895 N.W.2d 592 Minn. 2017
- State of Minnesota v. Andre Verlin Anderson Minn. Ct. App. 2017
- Ricardo Amigon-Vidal v. State of Minnesota Minn. Ct. App. 2017
- State of Minnesota v. Justin Dillard Thomas 890 N.W.2d 413 Minn. Ct. App. 2017
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State of Minnesota v. Justin Dillard Thomas
890 N.W.2d 413
Minn. Ct. App. 2017
In affirming the exclusion of this evidence, the Miles court relied on two earlier supreme court decisions
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Ricardo Amigon-Vidal v. State of Minnesota
Minn. Ct. App. 2017
(explaining in dicta that effective cross-examination, persuasive argument by defense counsel, proper jury instructions, and the requirement of jury unanimity are additional safeguards to ensure the reliability of eyewitness identification without the need to admit expert testimony regarding the r
- State of Minnesota v. Edwin Gochingco Reyes 890 N.W.2d 406 Minn. Ct. App. 2017
- State of Minnesota v. Edwin Gochingco Reyes 890 N.W.2d 406 Minn. Ct. App. 2017
- State of Minnesota v. Joshua Williams Wermers Minn. Ct. App. 2016
- State of Minnesota v. Joshua Williams Wermers Minn. Ct. App. 2016
- State of Minnesota v. Eddie Matthew Mosley 853 N.W.2d 789 Minn. 2014
- State of Minnesota v. Eddie Matthew Mosley 853 N.W.2d 789 Minn. 2014
- State v. Hayes 831 N.W.2d 546 Minn. 2013
- Doe v. Archdiocese of Saint Paul & Minneapolis 817 N.W.2d 150 Minn. 2012
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Doe v. Archdiocese of Saint Paul & Minneapolis
817 N.W.2d 150
Minn. 2012
When interpreting this older version of the rule, we often stated that “the basic requirement of Rule 702 is the helpfulness requirement.” MacLennan, d at 233 (); see also
- State v. Ferguson 804 N.W.2d 586 Minn. 2011
- State v. Obeta 796 N.W.2d 282 Minn. 2011
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State v. Obeta
796 N.W.2d 282
Minn. 2011
“[Ejxpert testimony is not helpful if the expert opinion ‘is within the knowledge and experience of a lay jury and the testimony of the expert will not add precision or depth to the jury’s ability to reach conclusions.’ ” ().
- State v. Anderson 789 N.W.2d 227 Minn. 2010
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State v. Anderson
789 N.W.2d 227
Minn. 2010
will not add precision or depth to the jury’s ability to reach conclusions.”
- State v. SONTOYA 788 N.W.2d 868 Minn. 2010
- State v. SONTOYA 788 N.W.2d 868 Minn. 2010
- Hayes v. Commissioner of Public Safety 773 N.W.2d 134 Minn. Ct. App. 2009
- Hayes v. Commissioner of Public Safety 773 N.W.2d 134 Minn. Ct. App. 2009
- State v. Hakala 763 N.W.2d 346 Minn. Ct. App. 2009
- State v. Hakala 763 N.W.2d 346 Minn. Ct. App. 2009
- State v. MacLennan 702 N.W.2d 219 Minn. 2005
- State v. MacLennan 702 N.W.2d 219 Minn. 2005
- State v. Moore 699 N.W.2d 733 Minn. 2005
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State v. Moore
699 N.W.2d 733
Minn. 2005
Expert opinion testimony is not helpful if “the subject of the testimony is within the knowledge and experience of a lay jury and the testimony of the expert will not add precision or depth to the jury’s ability to reach conclusions about that subject which is within their experience.”
- State v. Reese 692 N.W.2d 736 Minn. 2005
- State v. Reese 692 N.W.2d 736 Minn. 2005
- State v. DeShay 669 N.W.2d 878 Minn. 2003