Cited by

n.1 (Minn. 2009), the defendant raised the possibility of an alternative perpetrator in cross-examination by casting doubt on the identification of the shooter, and the State, in its closing argument, discussed the possibility that the defendant would argue that another person committed the crime.

XI, and Minn. Const. art. I, § 6; (“A defendant has the constitutional right to present a complete defense.”).

“Even if [appellate courts] determine that the district court abused its discretion, [appellate courts] must further find that the error was not harmless beyond a reasonable doubt to reverse the district court’s decision.” Id.; 592 (Minn. 2009) (explaining that, “[i]f [an appellate court] conclude[s] that the [district] court erred, [it] must then determine whether the error was harmless”).

XIV; Minn. Const. art. I, § 7; (“A defendant has the constitutional right to present a complete defense.”).

See, -94 (Minn. 2009) (holding that rap lyrics written by a defendant while he was incarcerated and awaiting trial were properly admitted as consciousness-of-guilt evidence).

The purpose of the alternative-perpetrator defense is not to establish “the alternative perpetrator’s guilt, but to create a reasonable doubt as to the defendant’s guilt.”

“A [criminal] defendant has the constitutional right to present a complete defense.”

12 In contrast, here the officer’s testimony was “fleeting, nonspecific, and minimally prejudicial.”

“[ A] defendant has the right to make all legitimate arguments on the evidence, to explain the evidence, and to present all proper inferences to be drawn therefrom.” (quotation omitted).

“[T]he district court has the discretion to limit the scope of closing argument to protect the jury from misleading inferences.” ( ) (other citation omitted).

DECISION “A defendant has the constitutional right to present a complete defense.”

(stating rule in context of evidentiary challenge based on the constitutional right to present complete defense)

XIV; (“A defendant has the constitutional right to present a complete defense.”).

Noor is correct that defendants have a “constitutional right to present a complete defense.”

(determining the alleged misconduct was harmless because the prosecutor made no attempt to elicit the impermissible testimony again after the objection was sustained and did not refer to the answer at any other point during trial); (noting where a police officer’s reference to prohibited testimony was “fleeting, nonspecific, and minimally prejudicial .

But “[a] defendant’s right to present a complete defense is not absolute.”

In State v. Atkinson, the supreme court held that a police officer’s references to the appellant’s previous arrests did not affect the appellant’s substantial rights because the references were “fleeting, nonspecific, and minimally prejudicial, if at all.” d 584, 596 (Minn. 2009).

See State v. Atkinson , (rejecting reverse -Spreigl evidence being offered solely to show a propensity for 2 White cites to State v. Sims to support his argument that simple shoplifting constitutes a crime of dishonesty, but Sims held the exact opposite.

See, -91 (Minn. 2009) (considering time and place of murder for foundation of alternative-perpetrator evidence); (determining no inherent tendency connected third party to charged crime because proposed evidence did not show third party was at or near the crime

d 584, 589 (Minn. 2009).

(“A defendant’s right to present a complete defense is not absolute.”) .

In closing argument, a criminal defendant has a right “to make all legitimate arguments on the evidence, to explain the evidence, and to present all proper inferences to be drawn therefrom.” (quotation omitted).

See State v. Atkinson , (notin g that references to appellant’s previous arrests were not unfairly prejudicial where the references were “fleeting” and “nonspecific”); see also State v. Budreau , (stating that there is a presumption that the jury follows the district court’s instructions

Like all defendants accused of criminal behavior, Meyer “has the constitutional right to present a complete defense.”

Similarly, “[m]ere presence at the scene of the crime does not, by itself, create an inherent tendency to connect a person alleged to be the alternative perpetrator to the commission of the charged crime.”

“Determining whether alternative perpetrator evidence was improperly excluded at trial involves a two -step analysis.” State v. Atkinson

An “error is harmless if the jury’s verdict is surely unattributable to the error.”

And the district court “may limit the scope of a defendant’s arguments to ensure that the defendant does not confuse the jury with misleading inferences.”

State v. Atkinson , 13 (Minn. 2009).