Cited by

We “independently review[ ] the facts to determine the reasonableness of the conduct of police in making the arrest.” State v. Jenkins , (quotation omitted).

6 (“The duty to preserve evidence only applies to evidence that is actually collected during the investigation of the crime because it would be illogical to require the [s]tate to preserve evidence it does not possess.” (quotation omitted)).

“A defend ant’s right to due process of law is implicated when the State loses, destroys, or otherwise failed to preserve material evidence.”

State v. Jenkins , , 223 (Minn. 2010) ("We review the district court's factual findings for clear error....").

luding “the details”—including proposed testimony about “why the federal charges were dismissed,” and that a Thief River Falls police officer “lied during the federal prosecution ”—on grounds of confusion of the issues and lack of personal knowledge.2 A district court “may limit the defendant’s evidence to ensure that the defendant does not confuse or mislead the jury.” State v. Jenkins , ; see Minn. R. Evid.

State v. Jenkins , -26 (Minn. 2010).

-23 (Minn. 2010) (quotation omitted).

But, as we have noted, “the evidence proffered in support of the defense must still comply with the rules of evidence.” (“[CJourts may limit the defendant’s evidence to ensure that the defendant does not confuse or mislead the jury.”).

XIV; Minn. Const. art. 1, § 7

“Evidentiary rulings are within the discretion of the district court and will not be overturned absent an abuse of that discretion.” State v. Jenkins , see also McDonald v. State , (holding that chain-of-custody issues are within the sound discretion of the district court), review denied (Minn. Oct.

“Evidentiary rulings are within the discretion of the district court and will not be overturned absent an abuse of that discretion.” d 658, 660 (Minn. App. 1984), review denied (Minn. Oct.

The appellate court’s “only consideration is whether the judge issuing the warrant had a substantial basis for concluding that probable cause existed.” -23 (Minn. 2010).

“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.” (quotation omitted).

(quoting Illinois v. Gates, 462 U.S. 213, 238 , 103 S.Ct.

-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”); (declining to “consider the remain

See, e.g., Youngblood, 488 U.S. at 52, 109 S. Ct. at 334 (semen samples); Trombetta, 467 U.S. at 481, 104 S. Ct. at 2530 (breath samples); -36 (Minn. 2010) (GPS data from taxicab, wallet, pair of shoes, car, pants, blood evidence on gun, biological material on bullets and bullet fragments); (car, information recorded in caller ID box).

For example, Osorio cites State v. Jenkins, in which the Minnesota Supreme Court stated that “[a] defendant’s right to due process of law is implicated when the State loses, destroys, or otherwise fails to preserve material evidence.”

at 836 (-30 (Minn. 2010)).

When reviewing the probable cause determination, we consider only “whether the judge issuing the warrant had a substantial basis for concluding that probable cause existed,” -23 (Minn. 2010) (quotation omitted), and, under the totality of the circumstances, we are “careful not to review each component of the affidavit in isolation,”

(d 335, 344 (Minn. 2009)).

Our only consideration is “whether the judge issuing the warrant had a substantial basis for concluding that probable cause existed.” -23 (Minn. 2010) (quotation omitted).