Cited by

901(a); (explaining that a district court does not abuse its discretion by refusing to admit an unauthenticated document into evidence).

(concluding the district court did not abuse its discretion in excluding evidence of a witness’s immigration status as bias evidence because the witness was not given consideration for his testimony); see also State v. Agudo , A22 -1151, 2023 WL 4199168 , at *6 -7 (Minn. App. June 26, 2023) (conc

“An erroneous jury instruction is harmless if, beyond a reasonable doubt, the instruction had no significant impact on the verdict rendered.” d 592, 601 (Minn. 2010).

Moreover— and for the sake of argument—even if B.E.’s anger issues and this statement could be loosely construed as motive evidence, “[e]vidence of motive alone does not have the inherent tendency to connect a third party to the commission of the crime.”

(in camera review of medical records); (evidentiary rulings); 4 (Schwartz hearing).

616 (evidence of bias); (“Evidence of bias of a witness is admissible to attack the credibility of a 18 If the protections of Rule 410 apply, “[t]here is no impeachment exception to the general rule that statements made in connection with plea negotiations are inadmissible.”

d 592, 597 (Minn. 2010).

See, (holding that the district court 30 did not abuse its discretion in denying the defendant’s motion to present an alternative-perpetrator defense when the defendant did not proffer evidence showing the alleged alternative perpetrator was “at or near the murder scene” or “had the opportunity” to m

-99 (Minn. 2010), the supreme court examined a district court’s decision to exclude evidence of a witness’s “immigration status and deportation hearing.” Like here, the defendant in Larson argued that the witness’s immigration status was probative of bias.

d 592, 601 (Minn. 2010) ( “If the court erred in its instructions, we review the error to determine whether it was harmless.”).

attenuated,” of “minimal relevance,” and “whatever probative value it has, it is substantially outweighed by the prejudicial impact.”

12 motivated by bias, “not everything tends to s how bias, and courts may exclude evidence that is only marginally useful for this purpose.”

(concluding the district court did not abuse its discretion by declining to admit unauthenticated transcripts into evidence).

The district court denied the requested instruction, reasoning that under State v. Larson , the instructi on was precluded as a matter of law because Montano intended to present evid ence identifying Gauthier as an alternative perpetrator.

But if the defendant “presents evidence and argues at trial that a witness is an alternative perpetrator, that witness is not an accomplice as a matter of law.”

Even though extrinsi c evidence may be used to show bias, “courts may exclude evidence that is only marginally useful for this purpose.” (q uotation omitted).

9 Lanz-Terry, at 640-41 (citation omitted) (affirming district court’s decision to limit cross - examination and exclude extrinsic evidence ); see also, d 592, 598-99 (Minn. 2010) (affirming district court’s decision to exclude extrinsic evidence because that evidence was too attenuated to support an argument of bias); (affirming district court ’s decision to disallow bia s- related cross-examination regarding whether one w

(holding that any error in instructing the jury did not affect the appellant’s substantial rights because the record containe d “considerable evidence” of her guilt).

We have previously held that “[e]vidence of motive alone does not have the inherent tendency to connect a third party to the commission of the crime.” Troxel, d at 309 ().

(addressing when a jury must be instructed regarding the need for corroboration of an accomplice’s testimony).

Further, “if the court erred in its instructions, we review the error to determine whether it was harmless.” State v. Larson

But “the district court may exclude any evidence, although relevant, for which the danger of unfair prejudice or misleading the jury substantially outweighs its probative value.” -99 (Minn. 2010) (citing Minn. R. Evid.

See State v. Larson , , 601-02 (Minn. 2010) (declining to consider whether the district court's use of jury instructions constituted an error that was plain because it concluded any alleged error was harmless).

Even though extrinsic evidence may be used to show bias , “not everything tends to show bias, and courts may exclude evidence that is only marginally useful for this purpose.” (quoting Lanz-Terry, d at 640).

“A district court’s exclusion of evidence is error if the exclusion is based on an abuse of discretion.”

“An accomplice instruction must be given if a witness could have reasonably been charged with and convicted of aiding and abetting the crime at issue.”

State v. Larson , –99 (Minn. 2010); see also Minn. R. Evid.

d 592, 603 (Minn. 2010).