Cited by

See State v. Palmer , (“Claims contained in a pro se supplement al brief with no argument or citation to legal authority in support of the allegations are deemed waived.” (quotation omitted)); (deeming waived argument raised for the first time in reply brief and not responsive to state’s briefing).

Compare State v. Yang , (reviewing objected-to evidence for harmless error) -98 (Minn. 2006) (reviewing for plain error when defendant fails to object at trial).

State v. Yang , State v. Nelson , review denied (Minn. Feb.

See State v. Yang , (noting that appellants may be entitled to a new trial in rare cases where the 10 “errors, when taken cumulatively, have the effe ct of denying [the] appellant a fair trial” (quotation omitted)).

See State v. Taylor , (“We deem arguments waived on appeal if a pro se supplemental brief contains no argument or citation to legal authority in support of the allegations” (quotation omitted)); (“An assignment of error based on mere assertion and not supported by any argument or authorities in appellant’s brief is waived and will not be 12 As discussed in Longo, the racketeering statute allows district courts to impose multiple sentences for

Issues that are r a i s e d f o r t h e f i r s t t i m e i n a n a p p e l l a n t ’ s r e p l y b r i e f a r e “ n ot proper subject matter for appellant’s reply brief and, therefore, [are] waived and strick en.” See State v. Yang , (striking an argument in appellant ’s reply brief because it raised a new issue).

See State v. Yang , (holding that issues raised for the first time in an appellant’s reply brief were deemed waived); (noting that inadequately briefed issues are not properly before an appellate court), review denied (Minn. Aug.

Davidson, d at 11; (explaining that, 7 under Minn. R. Evid.

see also State v. Yang , , 559 (Minn. 2009) ; State v. LaJambe , 300 Minn. 539 , , 919 (1974) (rejecting an instruction that the "testimony of an accomplice is considered inherently untrustworthy, primarily for the reason that he may testify against defendant in the hope of obtaining clemency for himself").

1 During closing argument s, a prosecutor may present “all legitimate arguments on the evidence and all proper inferences that ca n be drawn from that evidence.

3; State v. Yang , (granting motion to strike argument raised for the first time in appellant ’s reply brief).

“[I]t is improper for an expert to express an opinion that [a group] is a criminal gang under the statute, or that a defendant committed a crime to benefit a criminal gang because these opinions are the ultimate conclusions reserved for the jury.” State v. Yang

tted gang expert testimony because it "described gang culture generally, and the role of retaliation and respect in gang culture," even though other witnesses testified that the defendant was part of the gang, because "[the expert] did not offer his opinion regarding whether the murder of [the victim] was rooted in gang retaliation and did not directly implicate [the defendant]"); State v. Yang , , 556 (Minn. 2009) (stating that the expert "expressed his opinion that the primary activities of th

Moreover, “[a]n assignment of error based on mere assertion and not su pported by any argument or authorities in 4 appellant’s brief is waived and will not be considered on appeal unless prejudicial error is obvious on mere inspection.” (quotation omitted); see also State v. Bartylla , –23 (M inn.

And , appellate courts “will not disturb a district court’s decision to impose permissive cons ecutive sentences absent a clear abuse of discretion.”

d 539, 558 (Minn. 2009) (holding that this c ourt does not consider arguments made for the first time in a reply brief).

“An assignment of error based on mere assertion and not supported by any argument or authorities in appellant’s brief is waived and will not be considered on appeal unless prejudicial error is obvious on mere inspection.” (quotation omitted).

“To demonstrate ineffective assistance of counsel, appellant must show that (1) his counsel’s performance fell below an objective standard of reasonableness, and (2) that a reasonable probability exists that, but for his counsel’s unprofessional errors, the result of the proceedings would have been different.” -65 (Minn. 2009).

An appellant may be entitled to a new trial in rare cases where the “errors, when taken cumulatively, have,the effect of denying [the] appellant a fair trial.” When considering a. claim of cumulative, error, we look to the egregiohsness of the errors and .the strength of the State’s case.

But the right to cross-examine witnesses may be limited “so long as the jury is presented with sufficient information from which to draw inferences as to the witness’s reliability.” (quotation omitted).

But the right to cross-examine witnesses may b e limited “so long as the [fact finder] is presented wit h sufficient information from which to appropriately draw inferences as to the witness’s reliability.”

See, e.g., State v. Yang , (using the two phrases 14 testimony about the Snickers-bar incident, Jone s’s prior incarceration, the knife incident, and V.W.’s personal belief that Jones had committed the arson.

“[The] standard of review for claims of prosecu torial error depends on whether an objection was raised at the time of the alleged error.”

But the right to cross-examine witnesses may be limited as long as the jury is “presented with sufficient information from which to draw inferences as to witness reliability.”

(“The district court abuses its discretion in imposing consecutive sentences when the resulting sentence unfairly exaggerates the criminality of the defendant’s conduct.”).