Cited by

Richardson v. United States, 526 U.S. 813, 817 (1999); d 717, 730–31 (Minn. 2007).

“Jury verdicts in all criminal cases must be unanimous.”

Richardson v. United States, 526 U.S. 813, 817 (1999); –31 (Minn. 2007).

State v. Pendleton , –31 (Minn. 2007).

-26 (Minn. 2007) (observing that a district court’s review of a Batson challenge was “not in accordance with our Batson precedent” because, instead of making a determination whether the appellant had shown a prima facie case of racial discrimination after they gave their reasoning for the objection, the distric

If a district court “makes its determinations using the wrong legal standard, ‘we will examine the record without deferring to the district court’s analysis.’” Harvey, d at 811 (quoting 10 ).

11 not reflect all of the relevant circumstances that the court may consider.”

Price mainly relies on the Minnesota Supreme Court’s 5 for the proposition that, “[w]hen a district court does not make a ruling at each step in the process, the reviewing court must examine the record without deferring to the district court’s analysis.” Although the supreme court did refrain from applying deferential review in Pendleton, in which

20, 1988); -33 (Minn. 2007) (finding no error when district court did not require jury to agree unanimously on single purpose for which defendant acted if purpose could be satisfied by alternative means).

The supreme court has stated that it is “optimal procedure” for a district court to “make its rulings sequentially at the conclusion of its consideration of each prong[.]” n.11 (Minn. 2016) (d 717, 725 (Minn. 2007)).

This deference recognizes “that the record may not reflect all of the relevant circumstances that the court may consider.”

Minnesota jury verdicts must be unanimous on each element of the charged crime to support a conviction, –31 (Minn. 2007), but to conclude that an element has been proved beyond a reasonable doubt, “the jury need not always decide unanimously which of several possible means the defendant used to commit the offense,”

“Jury verdicts in all criminal cases must be unanimous.” (citing Minn. R. Crim.

19 “Jury verdicts in all criminal cases must be unanimous.” (citing Minn. R. Crim.

This deference recognizes “that the record may not reflect all of the relevant circumstances that the court may consider.”

But a jury does not have to unanimously “agree on the mode of commission of a crime.”

“To achieve that end, a jury must unanimously find that the [state] has proved each element of the offense.” -31 (Minn. 2007) (quotation omitted).

explanation,” (quotation omitted).

“To achieve that end, a jury must unanimously find that the government has proved each element of the offense.” -31 (Minn. 2007) (quotation omitted).

“To achieve that end, a jury must unanimously find that the government has proved each element of the offense.” -31 (Minn. 2007) (quotation omitted).

(holding 6 that a district court’s ruling on a Batson challenge is reviewed for clear error unless the district court “makes its determinations using the wrong legal standard”).

“Jury verdicts in all criminal cases must be unanimous.” (citing Minn. R. Crim.

This deference recognizes “that the record may not reflect all of the relevant circumstances that the court may consider.”

“To achieve that end, a jury must ‘unanimously find [] that the [state] has proved each element of the offense.’” d 717, 730-31 (Minn. 2007) (first alteration in original) (d 910, 918 (Minn. 2002)).

“To achieve that end, a jury must ‘unanimously find [ ] that the [state] has proved each element of the offense.” -31 (Minn. 2007) (first alteration in original) ().

(noting that unobjected -to jury instructions are reviewed for plain error).

1(5); - 31 (Minn. 2007).

d 717, 730 (Minn. 2007) (“Jury verdicts in all criminal cases must be unanimous.”); Minn. R. Crim.

Although a party usually must preserve a challenge to jury instructions by objecting to them before they are given, we “may consider plain error not brought to the district court’s attention if the error affects substantial rights.” (citing State v. Pendleton , (citing Minn. R. Crim.

district court’s statement, we examine the record without deferring to the district court’s analysis.5 We must consider whether the record could support a finding “that the peremptory challenge was ‘motivated by racial discrimination’ and that the State’s proffered explanation was ‘merely a pretext for the discriminatory motive.’ ” Diggins, d at 355 ().

-31 (Minn. 2007) (citing Minn. R. Crim.

The defendant must prove in the third step “that the peremptory strike was motivated by racial discrimination and that the proffered reasons were merely a pretext for the discriminatory motive.” State v. Pendleton , 6 (Minn. 2007) (quotation omitted).

“Jury verdicts in all criminal cases must be unanimous.”