Cited by
Opinions in Minnesota that cite State v. Underdahl, 767 N.W.2d 677.
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State of Minnesota v. Michael John Feehan
Minn. Ct. App. 2026
(concluding that dismissal of DWI charges demonstrated critical impact).
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State of Minnesota v. Joseph Archie Grenier
Minn. Ct. App. 2026
“The State can show critical impact when complying with an order significantly reduces the likelihood of a successful prosecution.” (quotation omitted).
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State of Minnesota v. Trevon James Mattson
Minn. Ct. App. 2026
-84 (Minn. 2009) (stating “an order that dismisses DWI charges, even when other charges remain, will have a critical impact on the prosecution’s case”).
- Followed Minnesota Coalition on Government Information v. City of Minneapolis, et al., Police Officers’ Federation of Minneapolis Minn. Ct. App. 2026
- Gary Lee Ambrose v. Shea Jerred Nettifee (A25-1601), Idlelee Renee Ambrose, vs. Shea Jerred Nettifee (A25-1602) Minn. Ct. App. 2026
- Gary Lee Ambrose v. Shea Jerred Nettifee (A25-1601), Idlelee Renee Ambrose, vs. Shea Jerred Nettifee (A25-1602) Minn. Ct. App. 2026
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State of Minnesota v. Stephen Kelly Weaver
Minn. Ct. App. 2026
“When the [s]tate appeals a pretrial order, it must 3 show clearly and unequivocally (1) that the district court’s ruling was erroneous and (2) that the ruling will have a ‘critical impact’ on the [s]tate’s ability to prosecute the case.” 3 (Minn. 2009); see Minn. R. Crim.
- State of Minnesota v. Raenard Romalle Douglas Minn. 2025
- State of Minnesota v. Raenard Romalle Douglas Minn. 2025
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State of Minnesota v. Cody Logan Fohrenkam
Minn. Ct. App. 2025
Although this requirement “is intended to be a demanding standard,” id., the state does not need to show “that conviction is impossible after the pretrial order.” d 677, 683 (Minn. 2009).
- State of Minnesota, Respondent, vs. Clifford Robert Letourneau, III, Appellant Minn. 2025
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State of Minnesota, Respondent, vs. Clifford Robert Letourneau, III, Appellant
Minn. 2025
(noting that the State has the burden of showing critical impact).
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Minn. 2025
(noting that the State has the burden of showing critical impact).
- State of Minnesota v. Derrick John Thompson Minn. Ct. App. 2025
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State of Minnesota v. Laryountae Eugene Taylor
Minn. Ct. App. 2025
“The critical impact requirement has evolved into a threshold issue, so that in the absence of critical impact [appellate courts] will not review a pretrial order.” (quotations omitted).
- State of Minnesota v. Christopher Lee Manska Minn. 2025
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State of Minnesota v. Christopher Lee Manska
Minn. 2025
We granted review solely on the issue of the evidence sought under Rule 9.01, and therefore the suppression issue is not before us. 5 we considered what constitutes an adequate showing under Rule 9.01, subd.
- State of Minnesota, Respondent, vs. Kyaw Be Bee, Appellant Minn. 2025
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State of Minnesota, Respondent, vs. Kyaw Be Bee, Appellant
Minn. 2025
(explaining that, in the absence of critical impact, we will not review the State’s challenge to a pretrial order).
- State of Minnesota v. Casimiro Sosa Saavedra Minn. Ct. App. 2024
- State of Minnesota v. Logan Hunter Vagle Minn. Ct. App. 2023
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State of Minnesota v. Logan Hunter Vagle
Minn. Ct. App. 2023
In a state pretrial appeal, the state “must show clearly and unequivocally (1) that the district court’s ruling was erroneous and (2) that the ruling will have a ‘critical impact’ on the State’s ability to prosecute the case.” ().
- Jacqueline Blakey, Jerry Blakey v. Javonda Jones, Gina Alexander, ... Minn. 2023
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Jacqueline Blakey, Jerry Blakey v. Javonda Jones, Gina Alexander, ...
Minn. 2023
Rules are read as a whole, and each section is interpreted “in light of the surrounding sections.” (internal quotation marks omitted) (quoting Am.
- State of Minnesota v. Ayyoob Dawood Abdus-Salam Minn. Ct. App. 2023
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State of Minnesota v. Kayli Anne Feekes-Benedict
Minn. Ct. App. 2023
And the district court, after giving the state a five-day stay, dismissed the charges against F eekes-Benedict, cementing the critical impact as it “destroy[ed] the state’s case.” Id.; (explaining that the dismissal of charges has a critical impact on the prosecution’s case).
- State of Minnesota v. Khyan Anwau Whitley Minn. Ct. App. 2023
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State of Minnesota v. James Michael Oliver
Minn. Ct. App. 2022
In order to prevail on a pretrial appeal, the prosecution “must show clearly and unequivocally (1) that the district court’s ruling was erroneous and (2) that the ruling will have a ‘critical impact’ on the State’s ability to prosecute the case.” State v. Underdahl , ().
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Craig David Halicki v. Commissioner of Public Safety
Minn. Ct. App. 2022
(Underdahl II), for the proposition that the DMT source code is relevant to the validity and reliability of his breath-test results .
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State of Minnesota v. Peggy Lynn Nelson
Minn. Ct. App. 2022
See State v. Underdahl , (“[A]n order that dismisses DWI charges, ev en when other charges remain, will have a critical impact on the prosecution’s case.”); see also Serbus, d at 87 (stating that “[b]ecause the district court dismissed the charge, critical impact is met”).
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David Patrick Curran v. Commissioner of Public Safety
Minn. Ct. App. 2021
An abuse of discretion occurs when “the district court erred by making findings unsupported by the evidence or by improperly applying the law.”
- Joel Leslie Wells v. Jeffrey Fischbach Minn. Ct. App. 2021
- Richard W Bandimere, et al v. Anita Summerville, A Summerville Realty Corporation d/b/a Summerville Realty Group Minn. Ct. App. 2021
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State of Minnesota
Minn. 2021
“When the State appeals a pre trial order, it must show clearly and unequivocally (1) that the district court’s ruling was erroneous and (2) that the ruling will have a ‘critical impact’ on the State’s ability to prosecute the case.” State v. Underdahl , see Minn. R. Crim.
- State of Minnesota v. Reginald Fanpatrick Wilson Minn. Ct. App. 2021
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State of Minnesota v. Kenny Alan Herold
Minn. Ct. App. 2020
(affirming order that required state to produce Intoxylizer source code).
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Michael Thomas Palke v. Commissioner of Public Safety
Minn. Ct. App. 2020
“But section 634.16’s presumption of reliability may be challenged in a proceeding under section 169A.53, subdivision 3(b)(10), which specifically permits a driver to challenge the reliability and accuracy of his or her test results.” Id.; n.4 (Minn. 2009).
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State of Minnesota v. Judana Catherine Williams
Minn. Ct. App. 2020
Critical impact “is intended to be a demanding standard, but with some flexibility.” d 677, 683 (Minn. 2009) (quotations omitted) .
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Bruce Andrew Olson v. Commissioner of Public Safety
Minn. Ct. App. 2019
Safety, n.4 (Minn. 2009).
- State v. Dexter 929 N.W.2d 455 Minn. Ct. App. 2019
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State v. Dexter
929 N.W.2d 455
Minn. Ct. App. 2019
State v. Underdahl , , 684 (Minn. 2009) ; State v. Rambahal , , 90 (Minn. 2008).
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State of Minnesota v. Steven Wayne Haney
Minn. Ct. App. 2019
State v. Underdahl , (“A district court judge has wide discretion to issue discovery orders, and normally an order will not be overturned without clear abuse of that discretion.” (quotati on omitted)); (“[Appellate courts] review a district court order regarding disc
- State v. Gosewisch 921 N.W.2d 796 Minn. Ct. App. 2018
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State v. Gosewisch
921 N.W.2d 796
Minn. Ct. App. 2018
State v. Underdahl , , 681 (Minn. 2009) ; see Minn. R. Crim.
- State of Minnesota v. Vincent Michael Gosewisch Minn. Ct. App. 2018
- Ries v. State 920 N.W.2d 620 Minn. 2018
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Ries v. State
920 N.W.2d 620
Minn. 2018
State v. Underdahl , , 681 (Minn. 2009).
- State of Minnesota v. Jennifer Susan Kline Minn. Ct. App. 2018
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State of Minnesota v. Steven David Schultz
Minn. Ct. App. 2018
To prevail, the state must show that (1) the district court “clearly and unequivocally” erred and (2) the error “will have a critical impact on the outcome of the trial.” (quotation omitted); see also Minn. R. Crim.
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State of Minnesota v. Daniel Eugene Meyer
Minn. Ct. App. 2018
“[T]his presumption [may] be challenged by drivers charged with DWI-related offenses.” n.4 (Minn. 2009).