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C. Relevance and Materiality The fourth requirement is that the evidence be “relevant and material to the state’s case.” (quotation omitted).

It is true that the supreme court has said “[w]hether the circumstances of the case raise an inference of discrimination depends in part on the races of the defendant and the victim.” abrogated on other grounds by Rivera v. Illinois, 556 U.S. 148, 129 S. Ct. 1446 (2009).

Cf. Wilson , d at 383 (stating that, at step one of the Batson analysis, "[t]he district court also had to consider potential bias against the State based on [the prospective Juror's] beliefs that in practice the criminal justice system does not work as well as it might and that the United States incarcerates a disproportionate number of African-American men"); see also Angus v. State , , 117 (Minn. 2005) (stating that the defendant's previous peremptory challenge to an African-American juror "w

The “mere fact that the veniremember subject to the strike is a racial minority does not establish a prima facie case of discrimination.” see also Reiners, d at 831.

“Whether the circumstances of the case raise an inference of discrimination depends in part on the races of the defendant and the victim.”

(“‘Need’ for other -crime evidence is not necessarily the absence of sufficient other evidence to convict .

One surrounding circumstance that Wilson suggests was present was a pattern by the State of'improperly striking all African American prospective jurors, However, in Angus v. State, we concluded that the “existence of a prior strike of a minority, based on race-neutral reasons that were not questioned, does not raise an inference that a subsequent strike of a minority was discriminatory.” (emphasis added).

(discussing common-la w rules of evidence in conjunction with the Minnesota Rules of Evidence).

“Whether the circumstances of the case raise an inference of discrimination depends in part on the races of the defendant and the victim.”

See, (concluding that the existence of prior strikes of racial minorities based on unchallenged race-neutral reasons or mere concern that “this would be the second African American juror” struck 22 by peremptory challenge was not enough to raise an infere

“Whether the circumstances of the case raise an inference of discrimination depends in part on the races of the defendant and the victim.” (finding disproportionate impact where four of seven male jury members were eliminated using peremptory strikes and thus establishing a prima facie case of gender discrimination).

The party challenging the strike must demonstrate that (1) “the proffered race- neutral reason is not the real reason for the strike” and (2) “the real reason was the race of the veniremember.”

The prima facie showing analysis also focuses on the racial overtones of the case, specifically, “[w]hether the circumstances of the case raise an inference of discrimination depends in part on the races of the defendant and the victim.” (holding that there were “no racial overtones” for Batson purposes where the defendant and victim were both white).

One of the requirements for admitting Spreigl evidence is that the district court “must identify the precise disputed fact to which the Spreigl evidence would be relevant.”

With regard to racial discrimination, “[w]hether the circumstances of the case raise an inference of discrimination depends in part on the races of the defendant and the victim.”

The party making a Batson challenge establishes a prima facie case of racial discrimination by showing that “(1) one or more members of a racial group have been peremptorily excluded from the jury, and (2) circumstances of the case raise an inference that the exclusion was based on race.”

See, -15 (Minn.2005); Reiners, d at 831 .

(prospective juror stricken because of expressed reluctance to sit in judgment of others); (venireperson stricken because he might favor police testimony).

“[T]he mere fact that the veniremember subject to the strike is a racial minority does not establish a prima facie case of discrimination.”