Cited by

“Erroneous admission of evidence that does not have constitutional implications is harmless if there is no reasonable possib ility that the wrongful ly admitted evidence significantly affected the verdict.” 4 (quotation omitted).

See Katz v. Katz , (“[W]e will not reverse a correct decision simply because it is based on incorrect reasons.”); (declining to reverse district court’s admission of statement even though reasoning was erroneous because statement was admissible on other grounds), aff’d

To determine whether the extrajudicial statement has circumstantial guarantees of trustworthiness equivalent to other hearsay exceptions, we follow the totality-of-the-circumstances approach, accounting for “all relevant factors bearing on trustworthiness.” (quotation omitted).

See Martinez, d at 737 (); review denied (Minn. Sept.

Next, to determine whether the district court abused its discretion in admitting A.H.’s statement under the residual-hearsay rule, this court applies “the totality of the circumstances approach” to determine whether the testimony bears “equivalent circumstantial guarantees of trustworthiness.”

5 (Minn. 1983) (holding that it was not plain error to fail to define “intent to kill” because it is “a phrase of common meaning,” and a definition would not greatly enhance the jury’s understanding); -800 (Minn. App. 2005) (concluding that the district court did not commit plain error by failing to define intent in assault case), aff’d on other grounds

When no constitutional right is implicated, the erroneous admission of evidence is harmless in the absence of a “reasonable possibility that the wrongfully admitted evidence significantly affected the verdict.” (quotation omitted).

See Martinez, d at 737 (); review denied (Minn. Sept.

e for purposes of medical diagnosis or treatment and describing medical history, or past or present symptoms, pain, or sensations, or the inception or general character of the cause or external source thereof insofar as reasonably pertinent to diagnosis or treatment.” “The rationale behind the rule is the patient’s belief that accuracy is essential to effective treatment.” (quotation omitted).

(construing Minn. R. Evid.

To determine whether the extrajudicial statement has circumstantial guarantees of trustworthiness equivalent to other hearsay exceptions, we follow the totality-of-the-circumstances approach, accounting for “all relevant factors 4 bearing on trustworthiness.” (quotation omitted).

d 400, 408 (Minn. 2006).

l court to fail to define ‘intent to kill,’ particularly where the definition that would have been given arguably does not add 10 much”); -800 (Minn. App. 2005) (concluding district court’s jury instructions did not constitute plain error by failing to define intent in assault case), aff’d on other grounds

An error is harmless if there is “no reasonable probability that the wrongfully admitted evidence significantly affected the verdict.” (quotation omitted).

-99 (Minn. App. 2005), aff’d, (affirming the district court’s decision to admit testimony when we “disagree[d] with the reasoning” used by the district court).

Courts look at the totality of the circumstances to determine whether a hearsay statement has “circumstantial guarantees of trustworthiness.” State v. 16 Robinson

See id.; -80 (Minn. App. 2005), aff’d in part, rev’d in part and remanded on other grounds

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