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d 419, 428 (Minn. 2009).

32 the prior bad act and the charged crime.”

“We presume a jury follows a court’s cautionary instruction.”3

8 Evidence of a defendant’s other acts may, however, be admissible under the immediate-episode exception “where two or more offenses are linked together in point of time or circumstances so that one cannot be fully shown without proving the other.” (quotation omitted).

4 4 In its postconviction decision

(noting that “the underlying purpose of the Spreigl notice is to avoid surprise to the defendant by giving him time to prepare a defense to the charges” (quotation omitted)).

and L.M.” When analyzing the effect of inadmissible Spreigl evidence, the supreme court has considered “whether the [s]tate presented other evidence on the issue for which the other crime evidence was offered.”

“Immediate-episode evidence” is a narrow exception to the general prior-bad-acts rule and allows the state to “prove all relevant facts and circumstances which tend to establish any of the elements of the offense with which the accused is charged, even tho ugh such facts and circumstances may prove or tend to prove that the defendant committed other crimes.” (quotation omitted) .

To obtain reversal of his conviction based on the erroneous admission of other-acts evidence, Bouanane must “demonstrate that the erroneous admission of evidence created a reasonable possibility that the wrongfully admitted evidence significantly affected the verdict.” (quotation omitted).

(concerning evidence admitted under the immediate episode exception); State v. Smith (Smith II), 13 (concerning evidence admitted under the Spreigl exception).

4 Section 634.20 provides for the admission of evidence of conduct by the accused against the victim of domestic abuse 4 We acknowledge that the statements might also constitute immediate episode evidence, see State v. Riddley , (describing immediate episode evidence as “a narrow exception to the general character evidence rule, ” allowing the admission of a prior bad act when “there is a close causal and temporal connection between the prior bad act and the charged crime”), but we need not addr

“[T]he underlying purpose of the [Spreigl] notice is to avoid surprise to the defendant by giving him time to prepare a defense to the charges.” (quotation omitted).

First, the district court issued a cautionary instruction to the jury just before the jury heard each piece of Spreigl evidence, explaining its “limited purpose.” “We presume a jury follows a court’s cautionary instruction.”

“We afford the district court broad discretion when ruling on evidentiary matters, and we will not reverse the district court absent an abuse of that discretion.” Doe 136 v. Liebsch

see also Andersen, d at 441-42(emphasizing the district court’s limiting instructions as well as the fact that the risk of unfair prejudice must “substantially outweigh” the probative value).

See State v. Riddley , (describing immediate-episode evidence as a narrow exception to the general character evidence rule, allowing the admission of a prior bad act when “there is a close causal and temporal connection between the prior bad act and the charged crime”).

When considering whether erroneously admitted evidence significantly influenced the jury’s verdict, appellate courts consider whether the di strict court gave a limiting instruction, the prosecutor “dwelled on the ev idence in closing argument[,] and whether the evidence of guilt was overwhelming.”

State v. Riddley , -27 (Minn. 2009) (determining that the evidence in question did not constitute immediate episode evidence— even though the acts occurred within a span of 15 minutes and at the same location — because the other acts did not facilitate the charged offenses); d 303, 316 -17 (determining t

See State v. Riddley , (permitting admission of immediate- episode evidence as exception to exclusion of bad-acts evidence).

“A defendant appealing the admission of evidence has the burden to show the 10 admission was both erroneous and prejudicial.” State v. Riddley

Not all references to prior bad acts constitute Spreigl evidence, and immediate-episode evidence is admissible “when there is a close causal and temporal connection between the prior bad act and the charged crime .” , 425 (Minn. 2009) ; see State v. Wofford , (“It is well recognized that the rule excluding evidence of the commission of other offenses does not necessarily deprive the state of the right to make out its whole case against the accused on any evidence which is otherwise relevant upo

State v. Benton , , 541 (Minn. 2015) (quoting State v. Riddley , , 428 (Minn. 2009) ).

e was harmless, the Minnesota Supreme Court examines four factors: (1) whether the state presented other evidence on the issue for which the evidence was offered; (2) w h e t h e r t h e r e w a s a n appropriate limiting instruction; (3) “whether the [s]tate dwel led on the evidence in [its] closing argument”; and (4) “whet her the evidence of guilt was o verwhelming.” 3 3 The parties both suggested a test with slightly different fact ors, drawn from State v. Peltier, which examines: “(1) the m

“Minnesota has long adhered to the common -law rule excluding evidence of prior bad acts except where the evidence fits within a specific exception.” ; see also Minn. R. Evid.

Appellate courts have “repeatedly affirmed the admission of immediate-episode evidence when there is a close causal and temporal connection between the prior bad a ct and the charged crime.”

ces so that one cannot be fully shown without proving the other, or where evidence of other crimes constitutes part of the res gestae , it is admissible.”); State v. Walsh , (“Arguably, the waitress incident was admissible as part of the occurrence or episode out of which the offense charged agai nst defendant arose.” (quotati on omitted)); -27 (Minn. 2009) (holding that the distric t court abused its discretion by allowing testimony regarding a prior robbery as immediate-episode evidence where

“Other relevant considerations are whether the State dwelled on the evidence in closing argument and whether the evidence of guilt was overwhelming.”

See State v. Riddley , -27 (Minn. 2009); State v. Wofford, 262 Minn. 112, 117-18