Cited by

(acknowledging that the supreme court’ s “power to reverse prophylactically or in the interests of justice comes from [its] power to supervise [district] courts” (quotation omitted)); n.6 (Minn. 2006) ( “The court of appeals does not exercise supervisory powers that are reserved to [the supreme] court.”).

5 “Prosecutors have an affirmative obligation to ensure that a defendant receives a fair trial, no matter how strong the evidence of guilt.”

(referring to the standard outlined in Ramey as “the modified plain-error test”).

is that [the] misconduct may deny the defendant’s right to a fair trial.” d 294, 30 0 (Minn. 2006).

Prosecutors are ministers of justice who “have an affirmative obligation to ensure that a defendant receives a fair trial, no matter how strong the evidence of guilt.”

An error is considered “plain” if it was “clear or obvious,” and this is typically established “if the error contravenes case law, a rule, or a standard of conduct.” (quotations omitted).

To do this, the state must show that there was “no reasonable likelihood that the absence of the misconduct in question would have had a significant effect on the verdict of the jury.” (quotation omitted).

(“An error is plain if,” at the time of the appeal, “it was clear or obvious,” which requires that “the error contravenes case law, a rule, or a standard of conduct.” (citations omitted) (internal quotation marks omitted)).

is that [the] misconduct may deny the defendant ’s right to a fair trial.” d 294, 30 0 (Minn. 2006).

Usually this is shown if the error contravenes case law, a rule, or a standard of conduct.” (quotations and citation omitted).

6 An error is plain if it is “clear and obvious,” which is typically shown by establishing that the decision at issue “contravenes case law, a rule, or a standard of conduct.”

A prosecutor is a “minister of justice whose obligation is to guard the rights of the accused as well as to enforce the rights of the public.” (quotation omitted).

“Usually this is shown if the error contravenes case law, a rule, or a standard of conduct.”

d 145, 157 (Minn. 2024) (- 300 (Minn. 2006)).

In other words, the state must show “there is no reasonable likelihood that the absence of the misconduct in question would have had a significant effect on the verdict of the jury.” (quotation omitted).

We apply “the plain error doctrine when examining unobjected-to prosecutorial misconduct.”

“An error is plain if it [i]s clear or obvious, ” which is usually established “if the error contravenes case law, a rule, or a standard of conduct.” (quotation omitted).

The Portillo court applied the four-step modified plain-error standard of review that applies to claims of unobjected -to prosecutorial misconduct

Finally, if the prosecutorial misconduct was plain error that affected substantial rights, a reviewing court “then assesses whether it should address the error to ensure fairness and the integrity of the judicial proceedings.” ().

Under this standard Cloar has the burden to “demonstrate both that error occurred and that the error was plain.”

“An error is plain if it was clear or obvious” and is typically established where the prosecutor’s conduct “contravenes case law, a rule, or a standard of 4 conduct.” (quotations omitted).

B. Unobjected-to Prosecutorial Misconduct If the defendant does not object during trial, we “review the prosecutor’s statements under a modified plain error analysis.” (-300, 302 (Minn. 2006)).

5 For unobjected-to prosecutorial misconduct, “[w]e review the prosecutor’s statements under a modified plain error analysis.” (-300, 302 (Minn. 2006)).

An error is plain if it is “clear or obvious,” (citation omitted) (internal quotation marks omitted), meaning the error “contravenes case law, a rule, or a standard of conduct.”

d 294, 299-300 (Minn. 2006) .