Cited by

If the district court erroneously admitted evidence, this court will reverse only if there is a “reasonable possibility that the wrongfully admitted evidence significantly affected the verdict.” (quotation omitted).

aff’d, d 400 (Minn. 2006).

If we determine that the district court erroneously admitted evidence, reversal is only warranted when there is a “reasonable possibility that the wrongfully admitted evidence significantly affected the verdict.”

When evaluating whether a statement is reliable at the first step of the residual- hearsay analysis, an appellate court focuses on the totality of the circumstances, “looking to all relevant factors bearing on trustworthiness to determine whether the extrajudicial statement has circumstantial guarantees of trustworthiness.” (quotations omitted).

18 In State v. Robinson, our supreme court explained that the rationale behind this rule “stems from the belief that if the original identification procedures were conducted fairly, the prior identification would tend to be more probative than an identification at trial.” (quotation omitted).

Vangrevenhof, d at 736; -09 (Minn. 2006) (instructing that the Ortlepp factors are nonexclusive).

To determine whether a statement has “equivalent circumstantial guarantees of trustworthiness,” appellate courts should consider the totality of the circumstances, “looking to all relevant factors bearing on trustworthiness.” (quotation omitted) .

(holding that statement of identity is not admissible under medical- diagnosis exception to hearsay rule when foundation to establish identity of person who caused injury is insufficient).

The rationale behind the medical-diagnosis exception is “the patient’s belief that accuracy is essential to 6 effective treatment.” (quotation omitted).

803(4); (explaining that rule 803(4) requires an evidentiary foundation to establish that the hearsay statement “was reasonably 7 pertinent to the medical diagnosis or treatment”).

First, the district court must “look at the totality of the circumstances to determine whether [the] hearsay statement has ‘circumstantial guarantees of trustworthiness.’” ().

An error is harmless if “there is no reasonable possibility that the wrongfully admitted evidence significantly affected the verdict.” -92 (Minn. App. 2011) (), rev denied (Minn, Jan.

In determining whether the erroneous admission of evidence was prejudicial or harmless, we consider whether ther e is “no reasonable possibility that the wrongfully admitted evidence significantly affected the verdict.” (quotation omitted) .2 An error is harmless if the jury could have reached the same “verdict ba sed on the other evidence .

In determining whether the erroneous admission of evidence was prejudicial or harmless, we consider whether there is “no reasonable possibility that the wrongfully admitted evidence significantly affected the verdict.” (quotation omitted).

See State v. Robinson , (“Erroneous admission of evidence that does not have constitutional implications is harmless if there is no ‘reasonable possibility that the wrongfully admitted evidence significantly affected the verdict.’” ( n.2 (Minn. 1994)).

This rule “does not extend to the out-of-court accusation against an o ffender whose identity was well-known to the victim.”

The rationale behind the medical-diagnosis exception is “the patient’s belief that accuracy is essential to effective treatment.” State v. Robinson , (quotation om itted).

“[S]tatements explaining the cause of an injury are admissible under the medical diagnosis exception, [but] statements attributing fault, including statements identifying the accused perpetrator, are ordinarily not admissible.”

See, e.g. , (upholding under rule 807 admission of statement given voluntarily, consistent across witness’s two accounts, not inspired by a motive to lie, and told consistently to two people in short amount of time) .

See id.; see also, -10 (Minn. 2006) ( affirming as harmless error the admission of evidence under an improper hearsay exception because the evidence was admissible under a different exception not mentioned by the district court); -44 (Minn. 1985) (affirming where a statement was inappropri

(quoting State v. Robinson , 9 (Minn. 2006) ).

(striking the state’s citation to a publication that was “evidentiary in nature,” not part of the record, and not “the type of information that is subject to judicial notice”).

aff’d, (declining to reverse district court’s admissi on of statement even though reasoning was erroneous because statement was admissible on other grounds); (M inn.

The rationale behind the medical-diagnosis exception is “the patient’s belief that accuracy is essential to effective treatment.” State v. Robinson , d 400, 404 (Minn. 2006) (quotation omitted).

" Davis , d at 181 (quoting State v. Robinson , , 408 (Minn. 2006) ).

Courts use “the totality of the circumstances approach, looking to all relevant factors bearing on trustworthiness to determine whether the extrajudicial statement has circumstantial guarantees of trustworthiness.” State v. Robinson

In determining whether a statement falls under the residual exception, Minnesota courts are to consider the totality of the circumstances, “looking to all relevant factors bearing on trustworthiness to determine whether the extrajudicial statement has circumstantial guarantees of trustworthiness equivalent to the other Rule 803 hearsay exceptions.” (quotation omitted).