Cited by
Opinions in Minnesota that cite State v. Bell, 719 N.W.2d 635.
- State of Minnesota, Respondent, vs. Toman Davin Matthews, Appellant. Minn. Ct. App. 2022
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State of Minnesota, Respondent,
Minn. Ct. App. 2022
section 634.20 provide s that “[e]vidence of domestic conduct by the accused against the victim of domestic conduct, or against other family or household members, is admissible unless the probative value is substantially outweighed by the danger of unfair prejudice.” Evidence admi ssible pursuant to Minn. Stat. § 634.20 is commonly referred to as “relationship evidence.” n.4 (Minn. 2006) (not ing that “evidence admitted under section 634.20 is a subtype of general relationship evidence”).
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State of Minnesota, Respondent,
Minn. Ct. App. 2022
“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).
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State of Minnesota, Respondent,
Minn. Ct. App. 2021
n.4 (Minn. 2006) (noting that “evidence admitted under section 634.20 is a subtype of general relationship evidence”).
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State of Minnesota, Respondent,
Minn. Ct. App. 2021
“[U]nfair pr ejudice is not merely damaging evidence, even severely damaging evidence; rather, unfai r prejudice is evidence that persuades by illegitimate means, giving one party an unfair advantage.” (quotation omitted).
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State of Minnesota, Respondent,
Minn. Ct. App. 2021
n.4 (Minn. 2006) (noting that evidence offered under section 634.20 is a subtype of ge neral relationship evidence).
- State of Minnesota, Respondent, Minn. Ct. App. 2021
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State of Minnesota, Respondent,
Minn. Ct. App. 2021
The question before us is not whether the evidence pr ejudiced Jones’s case, but rather whether it “persuades by illegitimate means, giving one party an unfair advantage.” State v. Bell , (quot ation omitted).
- State of Minnesota, Respondent, Minn. Ct. App. 2020
- State of Minnesota, Respondent, Minn. Ct. App. 2020
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State of Minnesota, Respondent,
Minn. Ct. App. 2020
Illegitimate means include “giving one party an unfair advantage.” State v. Bell , (quotations omitted).
- State of Minnesota, Respondent, Minn. Ct. App. 2019
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State of Minnesota, Respondent,
Minn. Ct. App. 2019
But section 634.20 describes only one “subtype of general relationship evidence.” -39 n.4 (Minn. 2006).
- State of Minnesota, Respondent, Minn. Ct. App. 2019
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State of Minnesota, Respondent,
Minn. Ct. App. 2019
“When balancing the probative value against the potential prejudice, unfair prejud ice 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.” State v. Bell , (quotation omitted).
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State of Minnesota, Respondent,
Minn. Ct. App. 2019
“When balancing the probative value against the potential prej udice, unfair prejudice is not merely damaging evidence, even severely damagi ng evidence; rather, unfair prejudice is evidence that persuades by illegitimate means, giving one party an unfair advantage.” State v. Bell , (quotation omitted).
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State of Minnesota, Respondent,
Minn. Ct. App. 2019
Evidence of past violence by the defendant against the same vic tim has “inherent value.”
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State of Minnesota, Respondent,
Minn. Ct. App. 2019
Moreover, evidence is not unfairly prejudicial unless it “persuades by illegitimate means, giving one party an unfair advantage.” (quotation omitted).
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State of Minnesota, Respondent,
Minn. Ct. App. 2019
lving SSW because the probative value, if any, was substantially outweighed by the 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 i s evidence that persuades by illegitimate means, giving one party an unfair advantage.” (quotation omitted).
- State of Minnesota, Respondent, Minn. Ct. App. 2018
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State of Minnesota, Respondent,
Minn. Ct. App. 2018
But relationship ev idence under Minn. Stat. § 634.20 is only “a subtype of general relationship evidence.” d 635, 638 n.4 (Minn. 2006).
- State of Minnesota, Respondent, Minn. Ct. App. 2018
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State of Minnesota, Respondent,
Minn. Ct. App. 2018
Relationship evidence under Minn. Stat. § 634.20 is only “a subty pe of general relationship evidence.” - 39 n.4 (Minn. 2006).
- State v. Patzold 917 N.W.2d 798 Minn. Ct. App. 2018
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State v. Patzold
917 N.W.2d 798
Minn. Ct. App. 2018
State v. Bell , , 641 (Minn. 2006) (quotation omitted).
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State of Minnesota, Respondent,
Minn. Ct. App. 2018
“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).
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State of Minnesota, Respondent,
Minn. Ct. App. 2018
“[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.” State v. Bell , (quotation omitted).
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State of Minnesota, Respondent,
Minn. Ct. App. 2018
This evidence was admitted as r elationship evidence, evidence that has “generally been used to describe any evidence that is offered to illuminate the relationship betwe en the accused and the alleged victim.” 8 n.4 (Minn. 2006).
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State of Minnesota, Respondent,
Minn. Ct. App. 2018
“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.” State v. Bell
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State of Minnesota, Respondent,
Minn. Ct. App. 2018
lows a court to admit evidence of another crime, wrong, or act to prove “motive, opportunity, intent, preparation, plan, knowledge, identity, or absence of mistake or accident.” Relationship evidence is a subset of 404(b) evidence and has “generally been used to describe any evidence that is offered to illuminate the relationship between the accused and the alleged victim.” State v. Bell , d 635, 638 n.4 (Minn. 2006).
- State of Minnesota, Respondent Minn. Ct. App. 2017
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State of Minnesota, Respondent,
Minn. Ct. App. 2017
Although the presentation of the DANCO may ha ve been damaging to Hancock’s defense, unfair prejudice “is not merely damaging evidence, [or] even severely damaging evidence; rather, unfair prejudice is evidence that persuades by illegitimate means, giving one party an unfair advantage.” See State v. Bell , (quotation omitted).
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State of Minnesota, Respondent,
Minn. Ct. App. 2017
Matthews, d at 553; see also State v. Bell , (“Evidentiary rulings rest within the discretion of the trial court and will not be reversed absent a clear abuse of discretion.”).
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State of Minnesota, Respondent,
Minn. Ct. App. 2017
Relationship evidence is “any evidence offered to illuminate the relationship between the accused and the alleged victim.” n.4 (Minn. 2006).
- State of Minnesota, Respondent, Minn. Ct. App. 2017
- State v. Fraga 898 N.W.2d 263 Minn. 2017
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State v. Fraga
898 N.W.2d 263
Minn. 2017
(stating that unfair prejudice means evidence that persuades the jury “by illegitimate'means, giving one party an unfair advantage” (citation omitted) (internal quotation marks omitted)).
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State of Minnesota, Respondent,
Minn. Ct. App. 2017
abused its discretion by admitting the three prior incidents as relationship evidence because their probative value was outweighed by their prejudicial effec t. In this context, unfairly prejudicial evidence means more than damaging, or even severely damaging, evidence; rather, it refers to evidence that “persuades by illegitimate means, giving one party an unfair advantage.” (quotation omitted).
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Travis Clay Andersen, petitioner, Appellant,
Minn. Ct. App. 2017
As such, they were admissible under Minn. Stat. § 634.20 (2014) as relationship evidence unless their “probative value [was] substantially outweighed by the danger of unfair prejudice.”
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State of Minnesota, Respondent,
Minn. Ct. App. 2017
In the context of Spreigl evidence, unfair prejudice “is not merely damaging evidence, even severely 4 damaging evidence; rather, unfair prejudice is evidence that persuades by illegitimate means, giving one party an unfair advantage.” (quotation omitted).
- State of Minnesota, Respondent, Minn. Ct. App. 2017
- State of Minnesota v. Christopher Paul Hilton Minn. Ct. App. 2017
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State of Minnesota v. Christopher Paul Hilton
Minn. Ct. App. 2017
In the context of relationship evidence, unfair prejudice does not refer to evidence that is damaging, or even severely damaging; instead it refers to “evidence that persuades by illegitimate means, giving one party an unfair advantage.” (quotation omitted).
- State of Minnesota v. Joseph Greene Minn. Ct. App. 2017
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State of Minnesota v. Joseph Greene
Minn. Ct. App. 2017
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).
- State of Minnesota v. Tracee Chung Minn. Ct. App. 2016
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State of Minnesota v. Tracee Chung
Minn. Ct. App. 2016
Appellant correctly asserts that the Minnesota Supreme Court’s decision in Ness was an attempt “to move away from the undue emphasis [it] had previously placed on the strength or weakness of the state’s case.”
- State of Minnesota v. Nathan Charles Robert Schwartz Minn. Ct. App. 2016
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State of Minnesota v. Nathan Charles Robert Schwartz
Minn. Ct. App. 2016
“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).
- State of Minnesota v. Joseph Bullhead Minn. Ct. App. 2016