Cited by

11 concluding that “the district court did not abuse its discretion in admitting the challenged testimony”); -31 (Minn. 2010) (concluding in context of plain-error review that “the district court did not abuse its discretion or commit any error when it granted the State’s motion to exclude the evidence on relevance grounds”).

He cites the Minnesota Supreme Court’s decision in State v. Jenkins for the principle that the “admissibility [of alternative-perpetrator evidence] depends exclusively on whether the evidence offered by the defendant inherently connects an alternative perpetrator to the commission of the charged crime regardless of the strength of the State’s case.”

“[C]ourts may limit the defendant’s evidence to ensure that the defendant does not confuse or mislead the jury.” see Minn. R. Evid.

See Atkinson, d at 591-92 (concluding that evidence of the alternative perpetrator’s location at the scene of the crime connected him only to the location of the crime, not the crime itself); (stating that the defendant’s evidence “at most established that [the alleged alternative perpetrator] 6 was present [at the crime scene] at some point on the night of the charged crime” but did not connect him to the crime).

(describing the elements of first-degree premeditated murder); Minn. Stat. § 609.185(a)(1) (same).

We focus our review on “whether the judge issuing the warrant had a substantial basis for concluding that probable cause existed.” -23 (Minn. 2010) (quotation omitted).

(noting “there can be no question that an arrest pursuant to a valid warrant is supported by probable cause and is therefore reasonable”); n.2 (Minn. 2000) (“Because the deputies had an arrest warrant for [the defendant], and therefore had no discretion r

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

d 211, 224 (Minn. 2010).

The second step requires the district court to consider whether the evidence is admissible under the “ordinary rules of evidence.”

(noting that to satisfy the probable-cause standard, a search-warrant application must “include information establishing a nexus between the crime, objects to be seized and the place to be searched”).

“Elements bearing on this probability determination include information establishing a nexus between the crime, objects to be seized and the place to be searched.”

The supreme court determined the probative value of such evidence was substantially outweighed by the danger of unfair prejudice because it would create “a trial-within-a-trial.” Id.; (holding that a defendant’s constitutional right to present a complete defense “is not absolute; courts may limit the defendant ’s evidence to ensure that the defendant does not confuse or mislead the jur y”); (affirming the exclusion of evidence

Yet the right to a complete defense, we have held, “is not absolute.”

at 590–91, but “[t]his right is not absolute.”

“Elements bearing on this probability determination include information establishing a nexus between the crime, objects to be seized and the place to be searched.”

d 211, 221–22 (Minn. 2010).

at 385 (emphasis added) ( .

d 211, 224 (Minn. 2010) (holding that “[a]lthough the warrant application here misstates the location where the taxicab dropped the man and woman off, [nothing] in the record before us suggest[s] that the misstatement was deliberately or recklessly made or that the precise location of their drop off was material to estab

A defendant’s right to due process of law may be implicated if the state loses or destroys material evidence , , and the prosecution has a duty to disclose “favorable and material” evidence to the def ense, (citing Brady v. Maryland, 373 U.S. 83, 87 (1963)).

(rejecting a police misconduct argument that “was not made to the district court at the time it was considering admission of the motive evidence.”).

d 211, 235 (Minn. 2010) (citations omitted).

(citing State v. Buckingham , ).

“A defendant’s right to due process of law is implicated when the [s]tate loses, destroys, or otherwise fails to preserve material evidence.”

4 “Every defendant has a constitutional right to present a complete defense, including evidence tending to prove another person committed the crime .” State v. Jenkins , see generally Minn. R. Evid.

The state does not cite either of these exceptions to the warrant requirement, instead arguing that the entry into the apartment was justified and the officer’s .

.W.2d 356, 366 (Minn. 2016) (“A finding of fact is not clearly erroneous if it is reasonably supported by the evidence as a whole.”); (“[W]e review a postconviction court’s factual determinations under a clearly erroneous standard, and do not reverse those determinations unless they are not factually supported by the record.”); (holding that the district court’s pretrial findings were “supported by the record and are not clear error”).

including the veracity and basis of knowledge of persons supplying hearsay information, there is a fair probability that contraband or evidence of a crime will be found in a particular place .” State v. Jenkins , (quotations omitted).

This right, however, “is not absolute.”

“When reviewing a district court’s decision to issue a search warrant, [a reviewing court ’s] only consideration is whether the judge issuing the warrant had a substantial basis for concluding that probable cause existed.” d 211, 222-23 (Minn. 2010) (quotation omitted).