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For instance, d 97, 108 (Minn. 2005), we affirmed a first-degree murder conviction based on evidence that the defendant had a motive to commit the murder, had access to a murder weapon, and had a key to the victim’s residence, even though no direct evidence connected the defendant to the scene at the time of the murder.

And in State v. DeRosier, applying the “catchall exception,” the supreme court has noted that the district court should make findings on the enumerated requirements “on the record unless there is a waiver, explicitly or by silence, or the basis of the ruling is obvious.” d 97, 105 (Minn. 2005) (quotation omitted).

A statement is admissible under this exception only if there are “no suspicious circumstances suggesting a motive for the declarant to fabricate or misrepresent his or her thoughts.”

But “[w]hen the overall delay in bringing a case to trial is the result of the defendant’s actions, there is no speedy trial violation.” accord Osorio, d at 628–29.

The statement offered “need not be ‘essential’ to satisfy” this requirement; the question is “whether other admissible evidence on the same point could be obtained through reasonable efforts.” Hallmark, d at 294 ().

The supreme court has also advised that, when making rulings on admissibility under the residual exception, district courts “should make findings explicitly on the record unless there is a waiver, explicitly or by silence, or the basis of the ruling is obvious.” (quotation omitted).

(stating that “there is no speedy trial violation” if “overall delay in bringing a case to trial is the result of the defendant’s actions”).

24, 2011); (applying that principle to a motion for a “Rule 20 evaluation”).

(finding trial delays caused by COVID-related orders did not weigh against the State in Barker analysis); (finding no denial of right to speedy trial, in part, because defendant’s motions were significant reason for delay).

(concluding that where 22 delay “was occasioned by defense motions” and the defendant “never moved for a speedy trial,” the defendant’s speedy trial right was not violated).

In State v. DeRosier, the supreme court found that the “delay in bringing the matter to trial was occasioned by defense motions” and held that, “[w]hen the overall delay in bringing a case to trial is the result of the defendant’s actions, there is no speedy trial violation.”

XIV; Minn. Const. art. I § 7

(citation omitted); see also State v. DeRosier , (concluding th at a delay caused in part by a rule 20 evaluation did not violate the right to a speedy trial).

When a defendant challenges the sufficiency of the evidence to sustain a conviction, this court analyzes the record “to determine whether the evidence, when viewed in a light most favorable to the convicti on, was sufficient to permit the jurors to reach the verdict which they did.” ().

See, (affirming a first-degree murder conviction based on evidence that the defendant had a motive to commit the murder, had access to a murder weapon, and had a key to the victim’s residence, despite the fact that there was no evidence connecting the defendant to the scene at the time of the crime).

Rule 807 is the residual exception, otherwise known as a “catchall .” see also Minn. R. Evid.

VI; Minn. Const. art. I, § 6

State v. DeRosier , , 106 (Minn. 2005).

or the basis of the ruling is obvious.” (quotation omitted).

See State v. DeRosier , –08 (Minn. 2005) (applying harmless -beyond-a-reasonable-doubt standard and citing to Triplett in doing so)

To determine whether a delay deprived a defendant of his right to a speedy trial, we consider four factors: “(1) the length of the delay, (2) the reason for the delay, (3) whether the defendant asserted his or her right to a speedy trial, and (4) whether the delay prejudiced the defendant.” (citing Barker v. Wingo, 407 U.S. 514, 530-33, 92 S. 9 Ct. 2182, 2192-93 (1972)).

State v. DeRosier , (quotation omitted).

VI; Minn. Const. art. I, § 6

The declarant’s state of mind must be relevant to an issue of the case.” –05 (Minn. 2005) (quotat ion omitted).

Our review of a sufficiency-of-the-evidenc e challenge is “limited to a painstaking analysis of the record to determine whether the evidence, when view ed in a light most favorable to the conviction, wa s sufficient to permit the jurors to reach the verdict which they did.” (quotation omitted).

Our review of a sufficiency-of-the-evidenc e challenge is “limited to a painstaking analysis of the record to determine whether the evidence, when view ed in a light most favorable to the conviction, wa s sufficient to permit the jurors to reach the verdict which they did.” (quotation omitted).

“The right to a speedy trial is guaranteed by the Sixth Amendment to the United States Constitution and Article I, Section 6 of the Minnesota Constitution.”

d 97, 108 (Minn. 2005) (quotation omitted).

Our review of the sufficiency of the evidence is “limited to a painstaking analysis of the record to determine whether the evidence, when viewed in a light most favorable to the conviction, was sufficient to permit the jurors to reach the verdict which they did.” (quotations omitted).

“The right to a speedy trial is guarant eed by the Sixth Amendment to the United States Constitution and Article I, Secti on 6 of the Minnesota Constitution.” State v. 6 DeRosier

Our review of a sufficiency-of-the-evidenc e challenge is “limited to a painstaking analysis of the record to determine whether the evidence, when view ed in a light most favorable to the conviction, wa s sufficient to permit the jurors to reach the verdict which they did.” (quotation omitted).

P. 11.09 (b); -09 (Minn. 2005).

Our review of a sufficiency-of-the-evidence challenge is “limited to a painstaking analysis of the record to determine whether the evidence, when viewed in a light most favorab le to the conviction, was suffi cient to permit the jurors to reach the verdict wh ich they did.” (quotation omitted).

Appellate courts ’ review of a su fficiency-of-the-evidence challenge is “limited to a painstaking analysis of the record to determine whether the evidence, when viewed in a light most favorable to the conviction, was sufficient to permit the jurors to reach the verdict which they did.” (quotations omitted).

Our review of a sufficiency -of-the-evidence challenge is “limited to a painstaking analysis of the record to determine whether the evidence, when viewed in a light most favorable to the conviction, was sufficient to permit the jurors to reach the verdict which they did.” (quotation omitted).