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“Structural errors require automatic reversal.”

ce to the substantial rights of the challenging party.” Here, the district court articulated this legal standard, identifying bias as “a state of mind on the part of the juror, in reference to the case or to either party, which would prevent the juror from trying the issue impartially and without prejudice to the substantial rights of either party.” (Emphasis added) ( n. 2 (Minn. 2007)).

A structural error may require automatic reversal of a conviction because it “call[s] into question the very accuracy and reliability of the trial process.” (quotat ion omitted).

A district court may remove a juror if the juror “expresse[s] a ‘state of mind’ demonstrating ‘actual bias’ towards the case or either party.” ( n.2 (Minn. 2007)).

( n.2 (Minn. 2007)) (further citation omitted).

Bey asserts that claims of structural er ror are not subject to forfeiture, citing to our decision in State v. Brown in which we stated that “[s]tructural errors always invalidate a conviction whether or not a timely objection to the error was made.”

For instance, the Weaver Court noted that some errors are deemed structural because the error “always results in fundamental unfairness.” 137 S. Ct. at 1908 (identifying the right to an attorney in a criminal proceeding and the right to a reasonable doubt instruction as examples); see also State v. Brown , (stating in dicta that inclusion of a biased juror was structural error that required automatic reversal even after the defendant’s lawyer failed to challenge the juror for cause or exercise a

Compare State v. Benton , -41 (Minn. 2015) (concluding any error in closing courtroom was invited by defen dant and did not seriously affect fairness, integrity, or reputation of judicial proceedings), with State v. Brown , (“Structural errors always invalidate a conviction whether or not a timely objection to the error was made.

(quotation omitted).2 A. A true closure occurred.

“The bias of a single juror violates the defendant’s right to a fair trial.”

A violation of the right to a public trial “is considered a structural error that is not subject to a harmless error analysis,” State v. Bobo , and generally requires the automatic reversal of a conviction

(quoting State v. Brown , ).

“Structural errors require automatic reversal because such errors 19 call into question the very accuracy and reli ability of the trial process.” State v. Brown , (citation omitted) .

“The bias of a single juror violates the defendant’s right to a fair trial,” because the “impartiality of the adjudicator goes to the very integrity of the legal syst em.” State v. Brown

Structural errors generally require automatic reversal of a conviction “because such errors call into question the very accuracy and reliability of the trial process.” (quotation omitted).2 defendant’s right to a fair trial and the juror’s legitimate privacy interests in not disclosing deeply personal matters to the public.

When considering an insu fficiency-of-the-evidence claim appellate courts “make a painstaking review of the r ecord to determine whether the evidence and reasonable inferences drawn therefrom, viewed in a light most favorable to the verdict, were sufficient 6 to allow the jury to reach its verdict.”

When considering an insufficiency-of-the-evidence claim, appellate courts “make a painstaking review of the r ecord to determine whether the evidence and reasonable inferences drawn therefrom, viewed in a light most favorable to the verdict, were sufficient to allow the jury to reach its verdict.”

8 Henry W. McCarr & Jack S. Nordby, Minnesota Practice § 27:9 n.18 (4th ed. 2012) ().

Because the impartiality of the fact- finder implicates “the very integrity of the legal system[,] [t]he bias of a single juror violates the defendant’s right to a fair trial.” (citation omitted).

Under the traditional standard, “we make a painstaking review 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.”

When an appellant challenges the sufficiency of the evidence presented at trial, we undertake a “painstaking review of the record,” (), and review the evidence “to determine whether, given the facts in the record and the legitimate inferences that can be drawn from those facts, a [fact-finder] could reasonably conclude that the defendant was guilty of the offense charged.” -07 (Minn. 2014)

Thomas asserts that seating a biased juror is structural error and “[s]tructural errors always invalidate a conviction whether or not a timely objection to the error was made.” Consistent with the state’s contention, this court has recently held that it “will not consider whether a distri

CISION Sufficiency of Evidence On review of a sufficiency-of-evidence claim, we conduct “a painstaking review of the record to determine whether the evidence and reasonable inferences drawn therefrom, viewed in a light most favorable to the verdict, were sufficient to allow the jury to reach its verdict.” ().

1 (2012); d 625, 628 (Minn. 2007) (explaining that conspiracy is an agreement to commit a crime and an overt act in furtherance of the conspiracy).

Implied bias is a bias that is “conclusively presumed as a matter of law.” n.2 (Minn. 2007).

When assessing the sufficiency of the evidence, “we make a painstaking review of the record to determine whether the evidence and reasonable inferences drawn therefrom, viewed in a light most favorable to the verdict, were sufficient to allow the jury to reach its verdict.”

629 n. 2 (Minn.2007); (stating that the challenging party bears the burden to prove actual bias).

-29 (Minn.2007) (reversing a defendant's conviction because, absent speculation, there was no evidence as to an element of the offense).

“Structural errors require automatic reversal because such errors ‘call into question the very accuracy and reliability of the trial process.’ ” ( , 448 n. 8 (Minn.2006)) (other quotation omitted).