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“[U]nfair prejudice is not merely damaging evidence, even severely damaging evidence; rather, unfair prejudice is evidence that persuades by illegitimate means, giving one party an unfair advantage.” (quotation omitted).

See McCoy, d at 161 (“[W]e expressly adopt Minn. Stat. § 634.20 as a rule of evidence for the admission of evidence of similar conduct by the accused against the alleged victim of domestic abuse.”); (noting the distinctions between section 634.20 evidence and rule 404(b) evidence).

3 The Minnesota Supreme Court has “on numerous occasions recognized the inherent value of evidence of past acts of violence committed by the same defendant against the same victim.” (quotation omitted).

“When balancing the probative value against the potential prejudice, unfair prejudice is not merely damaging evidence, even severely damaging evidence; rather, unfair prejudice is evidence that persuades by illegitimate means, giving one party an unfair ad vantage.” (quotation omitted).

While the district court found the evidence was “unquestionably prejudicial,” it specifically determined that the evidence was not “unfairly prejudicial” because it “would [not] tend to persuade by illegitimate means.” (stating, “unfair prejudice is not merely damaging evidence, even severely damaging evidence; rather, unfair prejudice is evidence that persuades by illegitimate means, giving one party an unfair advantage”) (quotation omitted); d 640, 653 (Minn. App. 2025) (fin

The supreme court has explained that “[w] hen balancing the probative value against the potential prejudice, unfair prejudice is not merely damaging evidence, even severely damaging evidence; rather, unfair prejudice is evidence that persuades by illegitimate means, giving one party an unfair advantage.” (quotation omitted).

lenge to the admissibility of the section 634.20 evidence on the ground that it was not needed to strengthen the state’s case fails” because “the need for section 634.20 evidence is naturally considered as part of the assessment of the probative value versus prejudicial effect of the evidence.” (quotation omitted); (stating that “a separate analysis of need” is not required to admit evidence under section 634.20).

d 635, 641 (Minn. 2006) (noting that unfairly prejudicial evidence is “not merely damaging evidence,” but instead, “evidence that persuades by illegitimate means, giving one party an unfair advantage” (quotation omitted)).

Victim’s] mom lets him back in the house, and he sexually assaults her again.” (2) “And for somebody who’s going to sexually assault her in 2021 and come back and keep sexually assaulting her in 2022, he’s treating her like she doesn’t matter, and she does.” 9 is “inherent value [in] evidence of past acts of violence committed by the same defendant against the same victim.” (quotation omitted).

Ambuehl’s argument is unavailing because section 634.20 evidence is presumptively admissible, Andersen, d at 442, and is not subject to 6 the procedural safeguards applicable to 404(b) evidence; -39 (Minn. 2006).

“[U]nfair prejudice is not merely damaging evidence, even severely damaging evidence; rather, unfair prejudice is evidence that persuades by illegitimate means, giving one party an unfair advantage.” (quotation omitted).

Unfair prejudice exists when evidence is not merely damaging but instead “persuades by illegitimate means, giving one party an unfair advantage.” (quotation omitted).

As a preliminary matter, a district court is not required to “engage in an independent analysis of the state’s need for section 634.20 evidence before it is admitted.”

“[U]nfair prejudice is not merely damaging evidence, even severely damaging evidence; rather, unfair prejudice is evidence that persuades by illegitimate means, giving one party an unfair advantage.” (quotation omitted).

A similar argument was rejected in State v. Bell , when the supreme court declined to “require that trial courts consider the state’s need for the evidence before admitting evidence under section 634.20.”

-61 (Minn. 2004) (explaining that the “history of the relationship between an accused and a [domestic-violence] victim” differs from “collateral [other-acts] evidence” (quotation omitted)); (noting the “distinctions” made between rule 404(b) evidence and section 634.20 evidence).

n.4 (Minn. 2006) (describing evidence admissible under section 634.20 as a type of 10 “relationship evidence”).

“When balancing the probative value against the potential prejudice, unfair prejudice is not merely damaging evidence, even severely damaging evidence; rather, unfair prejudice is evidence that persuades by illegitimate means, giving one party an unfair advantage.”

(concluding that the district court acted within its discretion by admitting evidence of 12 incidents of domestic violence as relationship evidence pursuant to Minn. Stat. § 634.20); (concluding that OFP violations were probative evidence of the history of the relationship).

Relationship evidence is “any evidence of past conduct between the alleged victim and the accused that sheds light on the relationship between the two.” n.4 (Minn. 2006).

“When balancing the probative value against the potential prejudice, unfair prejudice is not merely damaging evidence, even severely damaging evidence; rather, unfair prejudice is evidence that persuades by illegitimate means, giving one party an unfair advantage.” (quotation omitted).

The supreme court has held that “admission of relationship evidence was not error, despite the fact that the trial court did not, on the record, engage in the probative value versus potential prejudice balancing test.” see also State v. O’Meara, (concluding that the district court’s failure to “recite the required balancing test” was “not erroneous”).

Unfair prejudice “is not merely damaging evidence, even severely damaging evidence; rather, unfair prejudice is evidence that persuades by illegitimate means, giving one party an unfair advantage.” ( quotation omitted).

See S n.4 (Minn. 2006) (noting relationship evidence is intended to “illuminate the relationship between the accused and the alleged victim”).

Unfair prejudice, however, “is not merely damaging evidence, even severely damaging evidence; rather, unfair prejudice is evidence that persuades by illegitimate means, giving one party an unfair advantage.” (quotation omitted).

Vang’s brief to this court argues that “the district court committed reversible error when it allowed the state to introduce relationship evidence.” “The term ‘relationship evidence’ has generally been used to describe any evidence that is offered to illuminate the relationship between the accused and the alleged victim.” n.4 (Minn. 2006).

“When balancing the probative value against the potential prejudice, unfair prejudice is not merely damaging evidence, even severely damaging evidence; rather, unfair prejudice is evidence that persuades by illegitimate means, giving one party an unfair advantage.” (quotation omitted).

Spreigl evidence is prejudicial by nature, but “unfair prejudice is not merely damaging evidence, even severely damaging evidence; rather, unfair prejudice is evidence that persuades by illegitimate means, giving one party an unfair advantage.” (quotation omitted).

Relationship evidence may give rise to unfair prejudice if the evidence “pe rsuades by illegitimat e means.” (quotation omitted).

(determining that evidence that the defendant twice violated an order for protection was “probative of a material fact, namely the history of [the defendant and victim’s] relationship”); -57 (Minn. App. 2008) (stating that evidence establishing the relationshi

“When balancing the probative value against the potential prejudice, unfair prejudice is not merely damaging evidence, even severely damaging evidence; rather, unfair prejudice is evidence that persuades by illegitimate means, giving one party an unfair advantage.” (quotation omitted).

ndant’s “verbal[] and physical[] abuse[]” of the victim “earlier in their relationship” had “obvious probative value” because it “informed the jury of the nature of their relationship, the times that [the victim] felt afraid of [the defendant], and the times that [the defendant] attempted to manipulate, control, and restrain her.” d 635, 641 (Minn. 2006) (determining that evidence that the defendant twice violated an order for protection was “probative of a material fact, namely the history of [

Spreigl evidence is prejudicial by nature, but “unfair prejudice is not merely damaging evidence, even severely damaging evidence; rather, unfair prejudice is evidence that persuades by illegitimate means, giving one party an unfair advantage.” (quotation omitted).

Finally, when balancing the probative value of the evidence against the potential unfair prejudice against the defendant in trial, unfair prejudice is not merely damaging or severely damaging evidence, it is “evidence that persuades by illegitimate means, giving one party an unfair advantage.” (quotation omitted).

6 Danger of Unfair Prejudice “When balancing the probative value against the potential prejudice, unfair prejudice is not merely damaging evidence, even severely damaging evidence; rather, unfair prejudice is evidence that persuades by illegitimate means, giving one party an unfair advantage.” (quotation omitted).

“When balancing the probative value against the potential prejudice, unfair prejudice is not merely damaging evidence, even severely damaging evidence; rather, unfair prejudice is evidence that persuades by illegitimate means, giving one party an unfair advantage.” (quotation omitted).

“When balancing the probative value against the potential prejudice, unfair prejudice is not merely damaging evidence, even severely damaging evidence; rather, unfair prejudice is evidence that persuades by illegitimate means, giving one party an unfair advantage.” (quotation omitted).

Riddley, d at 427; -42 (Minn. 2006) (explaining that procedural defects when admitting evidence generally are implicitly harmless if the evidence is otherwise admissible).

When balancing the probative value of the relationship evidence against potential for unfair prejudice to Vanengen, “unfair prejudice is [seen as] not merely damaging evidence, even severely damaging evidence; rather, unfair prejudice is evidence that persuades by illegitimate means, giving one party an unfair advantage .” (quotation omitted ).

In the context of relationship evidence under Minn. Stat. § 634.20, “[w]hen balancing the probative value against the potential prejudice, unfair prejudice is not merely damaging evidence, even severely damaging evidence; rather, unfair prejudice is evidence that persuades by illegitimate means, giving one party an unfair advantage.” (quotation omitted).

“[U]nfair prejudice is not merely damaging evidence, even severely damaging evidence; rather, unfair prejudice is evidence that persuades by illegitimate means, giving one party an unfair advantage.” (quotation omitted).

2(a) (2020); (stating that relationship evidence is not subject to Minn. R. Evid.

Minnesota Statutes section 634.20 (2020) establishes a “subtype of general relationship evidence.” State v. Bell , n.4 (Minn. 2006 ).

State v. Bell , n.4 (Minn. 2006).