Cited by
Opinions in Minnesota that cite State v. Hall, 722 N.W.2d 472.
- State of Minnesota v. Kenneth Gale Lanham Minn. Ct. App. 2026
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State of Minnesota v. Kenneth Gale Lanham
Minn. Ct. App. 2026
See, (“We have consistently held that when an erroneous jury instruction eliminates a required element of the crime this type of error is not harmless beyond a reasonable doubt.”); -59 (Minn. 2001) (concluding an error is not harmless if it removes the state’s burde
- State of Minnesota, Respondent, Minn. Ct. App. 2024
- State of Minnesota v. Sidney Phillip Monette Minn. Ct. App. 2024
- State of Minnesota v. Sidney Phillip Monette Minn. Ct. App. 2024
- State of Minnesota v. Elsa E. Segura Minn. 2024
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State of Minnesota v. Elsa E. Segura
Minn. 2024
However, “[a] mistaken jury instruction does not require a new trial if the error was harmless.”
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State of Minnesota, Respondent,
Minn. Ct. App. 2023
“A party is entitled to an instruction if the evidence produced at trial supports the instruction .” (citation omitted).
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State of Minnesota, Respondent,
Minn. Ct. App. 2023
“A mistaken jury instruction does not require a new trial if the error was harmless.”
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State of Minnesota,
Minn. 2023
–82 (Minn. 2006); see also Nancy Ehrenreich, Attempt, Merger, and Transferred Intent, 82 Brook.
- State of Minnesota, Respondent, Minn. Ct. App. 2022
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Minn. 2020
“Intent to kill may be inferred from the manner of the killing.” 12 see also State v. Harris , (finding intent to kill after considering the severity of injuries to the victim); (noting that in tent to cause death “may be inferred from the manner of shooting the victim”).
- 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. 2018
The doctrine of transferred intent “is the principle that a defendant may be convicted if it is proved he intended to injure one person but actually harmed another.” (quoting 9 Henry W. McCarr & Jack S. Nordby, Minnesota Practice § 44.8 (3d ed. 2001)).
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State of Minnesota, Respondent,
Minn. Ct. App. 2018
Transferred intent “is the principle that a defendant may be convicted if it is proved he intended to injure one person but actually harmed another.” d 472, 477 (Minn. 2006) (quotin g 9 Harry W. McCarr & Jack Nordby, Minnesota Practice § 44.8 (3d ed. 2001)).
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State of Minnesota, Respondent,
Minn. Ct. App. 2018
-78 (Minn. 2006) (noting that intent can be transferred in first -degree premeditated murder cases); -14 (Minn. App. 2013) (discussing that “Minnesota caselaw has consistently applied the doctrine of transferred intent to specific-intent crimes”), review denied (Minn. Aug.
- State of Minnesota v. Vernon Dale Howard, Sr. Minn. Ct. App. 2017
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State of Minnesota v. Vernon Dale Howard, Sr.
Minn. Ct. App. 2017
(“A mistaken jury instruction does not require a new trial if the error was harmless.”).
- State of Minnesota v. Quintin Lynn Thomas 882 N.W.2d 640 Minn. Ct. App. 2016
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State of Minnesota v. Quintin Lynn Thomas
882 N.W.2d 640
Minn. Ct. App. 2016
“An instruction is in error if it materially misstates the law,” but “[a] mistaken jury instruction does not require a new trial if the error was harmless.”
- State of Minnesota v. Jack Leonard Williams Minn. Ct. App. 2016
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State of Minnesota v. Jack Leonard Williams
Minn. Ct. App. 2016
An erroneous jury instruction is harmless only if it can be said that, beyond a reasonable doubt, the error had no significant impact on the verdict rendered.” (citation omitted).
- State of Minnesota v. Alexander Kenton Edmondson Minn. Ct. App. 2015
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State of Minnesota v. Alexander Kenton Edmondson
Minn. Ct. App. 2015
“[W]hen an erroneous jury instruction eliminates a required element of the crime this type of error is not harmless beyond a reasonable 4 doubt.”
- State of Minnesota v. Michael Jamah Griffis Minn. Ct. App. 2015
- State of Minnesota v. Michael Jamah Griffis Minn. Ct. App. 2015
- State of Minnesota v. Brian Leonard Anderson Minn. Ct. App. 2015
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State of Minnesota v. Brian Leonard Anderson
Minn. Ct. App. 2015
In light of these factors, the error is harmless if, “beyond a reasonable doubt, [it] had no significant impact on the verdict rendered.”
- State v. Watkins 840 N.W.2d 21 Minn. 2013
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State v. Watkins
840 N.W.2d 21
Minn. 2013
In reaching that conclusion, d *25 675 (Minn.2007), for the proposition that an omission of an element of a charged offense from the jury instructions “as a matter of law” affects a party’s substantial rights.
- State v. Bakdash 830 N.W.2d 906 Minn. Ct. App. 2013
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State v. Bakdash
830 N.W.2d 906
Minn. Ct. App. 2013
Transferred intent “is the principle that a defendant may be convicted if it is proved he intended to injure one person but actually harmed another.” (quoting *913 McCarr & Nordby, Minnesota Practice § 44.8 (3d ed.2001)).
- State v. Watkins 820 N.W.2d 264 Minn. Ct. App. 2012
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State v. Watkins
820 N.W.2d 264
Minn. Ct. App. 2012
In Mahkuk , the supreme court reaffirmed that it had “consistently held that when an erroneous jury instruction eliminates a required element of the crime[,] this type of error is not harmless beyond a reasonable doubt.” d at 683 ().
- State v. Carridine 812 N.W.2d 130 Minn. 2012
- State v. Carridine 812 N.W.2d 130 Minn. 2012
- State v. Caldwell 803 N.W.2d 373 Minn. 2011
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State v. Caldwell
803 N.W.2d 373
Minn. 2011
We have said “our rule for giving the transferred intent instruction requires that at the time of his actions the defendant intended to kill one person but instead accidentally killed another person.”
- State v. Koppi 798 N.W.2d 358 Minn. 2011
- State v. Koppi 798 N.W.2d 358 Minn. 2011
- State v. Cruz-Ramirez 771 N.W.2d 497 Minn. 2009
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State v. Cruz-Ramirez
771 N.W.2d 497
Minn. 2009
That doctrine, derived from the common law, stands for the principle that “ ‘a defendant may be convicted if it is proved he intended to injure one person but actually harmed another.’ ” (quoting 9 Henry W. McCarr & Jack S. Nordby, Minnesota Practice-Criminal Law and Procedure § 44.8 (3d ed.2001)).
- State v. Holliday 745 N.W.2d 556 Minn. 2008
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State v. Holliday
745 N.W.2d 556
Minn. 2008
Section 609.185 “incorporates the traditional doctrine of ‘transferred intent,’ ” under which “[premeditation will transfer with intent if the perpetrator premeditated the murder of an intended victim but accidentally, killed an unintended victim,”
- State v. Mahkuk 736 N.W.2d 675 Minn. 2007
- State v. Mahkuk 736 N.W.2d 675 Minn. 2007
- Francis v. State 729 N.W.2d 584 Minn. 2007
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Francis v. State
729 N.W.2d 584
Minn. 2007
But “[p]remeditation will transfer with intent if the perpetrator premeditated the murder of an intended victim but accidentally killed an unintended victim.”