Cited by

(“Character attacks are improper during closing argument.”); (stating evidence of prior bad acts may not be used “to attack the defendant’s character or to establish a criminal propensity”), rev. denied (Minn. May 16, 2000).

(agreeing with district court conclusion “that the evidence was not evidence of bad acts because there is nothing per se wrong with” the acts).

Really what this is, is evidence of his pain that he has in his life and the things that he has to do to manage his pain in his life.” In analyzing closing arguments for attorney misconduct, we must “look to the closing argument as a whole, rather than to selected phrases and remarks.”

When examining a prosecutor’s closing argument for instances of prosecutorial misconduct, this court “look[s] to the closing argument as a whole, rather than to selected phrases and remarks.” -20 (Minn. 2004).

A prosecutor’s “statement must be read in context,” and we look at “the closing argument as a whole, rather than to selected phrases and remarks.” -20 (Minn. 2004).

14 When assessing alleged misconduct during a closing argument, appellate courts “look to the closing argument as a whole, rather than to selected phrases and remarks.”

Ouellette next argues that the district abused its discretion by denying his request to modify the jury instruction about the use of the Spreigl evidence because modification requests from defendants seeking to limit the use of Spreigl evidence to appropriate purposes should be granted and the district court’s

“risked buttressing [P.M.’s] credibility by fixating the jury on her version, thereby persuading by illegitimate means.” In support of this argument

A prosecutor’s “statement 7 must be read in context,” and we look at “the closing argument as a whole, rather than to selected phrases and remarks.” -20 (Minn. 2004).

A Spreigl incident can be markedly similar in modus operandi without being “identical in every way to the charged crime,” so long as the Spreigl incident serves to “complete the picture of the defendant” and does not “paint another picture.” -16 (Minn. 2004) (quotation omitted).

When assessing alleged misconduct during a closing argument, we “look to the closing argument as a whole, rather than to selected phrases and remarks.”

(rejecting pro se arguments after thorough review of the record and without detailed discussion).

A prosecutor engages in misconduct when she mischaracterizes the evidence, or improperly refers to inadmissible evidence, d 9, 19 (Minn. 2004).

(explaining that when considering whether prosecutorial misconduct prejudiced a defendant, we “look to the closing argument as a whole, rather than to selected phrases and remarks”).

in which the Spreigl evidence was “practically a retrial” of the other crime when 24 witnesses testified to the details of that crime for almost three of the twelve days of trial.

There must be a “sufficiently close relationship between the charged offense and the Spreigl [act] in time, place, or modus operandi.” (quotation omitted).

(stating that the probative value of Spreigl evidence may be outweighed by the risk of unfair prejudice where it is merely cumulative); cf. Fardan, d at 319 (affirming the admission of other-acts evidence where it was “not so similar or presented with enough detail that it would cause the

But for Spreigl evidence to be both relevant and material, there must be a “sufficiently close relationship between the charged offense and the Spreigl [act] in time, place, or modus operandi.” 3 (quotation omitted).

For example, the Minnesota Supreme Court concluded that a prosecutor’s use of the pronoun “I” in closing argume nt was “an improper interjection of personal opinion into the argument.” but see State v. Anderson, 7 (“Here, the prosecutor’s prefatory phrase ‘I suggest’ is the equivalent to ‘I submit’ or ‘the state submits,’ which Minnesota courts have held are not impermissible expressions of opinion.”), aff’d on other grounds, d 12

See Ture v. State , (rejecting pro se arguments without detailed discussion).

See Koch v. O’Brien, 131 A.2d 63, 64-65 (N.H. 1957) (concluding that executive discretion under statute to grant or refuse rendition of a fugitive d id not violate separation -of-powers provision of state constitution); see also Ture v. State , (rejecting pro se arguments without detailing consideration of each argument).

(explaining that 8 where there is nothing “per se wrong” with the defendant’s actions, evidence of those acts is not Spreigl evidence).

11 See Ture v. State , (reje cting criminal defendant’s pro se arguments as meritless without detailed legal analysis).

Ture v. State , (concluding that evidence of defendant’s collection of personal information about women was not bad-act evidence because there was nothing per se wrong with the act).

(conclud ing that appellant’s pro se arguments were without merit after “a thorough review of the record and case law relevant to [appellant’s] arguments”).

See Brady v. Maryland, 373 U.S. 83, 87, 83 S. Ct. 1194, 1196 -97 (1963) (holding that the prosecution’s suppression of evidence favorable to the defendant violates due process when the evidence is material to guilt or punishment); (rejecting pro se arguments without detailed discussion).

’” Ture v. S tate, (quoting State v. Everett

-20 (Minn. 2004) (describing the “potential for prejudice” with Spreigl evidence as “inherent”).

" State v. McCray , , 751 (Minn. 2008) (quoting Ture v. State , , 19 (Minn. 2004) ).

(noting that courts look at “the closing argument as a whole, rather than to selected phrases and remarks .”).

” In analyzing closing arguments for misconduct, we must “ look to the closing argument as a whole, rather than to selected phrases and remarks .” Ture v. State

(rejecting pro se arguments without detailed discussion).

Specifically, a prosecutor “may not interject his or her personal opinion so as to personally attach himself or herself to the cause which he or she represents.” (quotation omitted).

See State v. Bartylla , (stating that this court “ will not consider pro se claims on appeal that are unsupported by either arguments or citations to legal authority ”); (rejecting pro se arguments without detailing consideration of each argument).

See Ture v. State , (rejecting remaining pro se arguments without discussing each argument ).

(stating that although a prosecutor may argue a witness’s credibility, she may not interject her personal opinion so as to attach herself to the cause she represents); d 717, 721 (Minn. App. 1997) (stating that it is misconduct for a prosecutor to characterize the defen

See Ture v. State , (rejecting pro se arguments based on review of record without detailing each claim).

See Ture v. State , (rejecting pro se claims without articulating reasoning for each claim).

In Ture v. State, the supreme court concluded that it was improper for the prosecutor to use “the first-person pronoun ‘I’ during closing argument” when addressing witness credibility because a prosecutor “may not interject his 15 or her personal opinion so as to personally attach himself or herself to the cause which he or she represents.” (quotation omitted).