Cited by

d 646, 651 (Minn. App. 2010), rev. denied (Minn. Oct.

(discussing the strength of the state’s evidence when assessing the risk of unfair prejudice posed by relationship evidence).

Regarding relationship evidence, “[e]vidence that helps to establish the relationship between the victim and the defendant or which places the event in context bolsters its probative value.” (quotation omitted), rev. denied (Minn. Oct 27, 2010).

-51 (Minn. App. 2010) , rev. denied (Minn. Oct.

9 in the past and specifically includes prior acts of “domestic abuse.” Minn. Stat. § 634.20; (“Evidence presented under section 634.20 is offered to demonstrate the history of the relationship between the accused and the victim of domestic abuse .”), rev. denied (Minn. Oct.

We note that the district court abused its discretion in finding that this evidence constitute d relationship evidence because Minn. Stat. § 634.20 “requires that the evidence address similar conduct by the accused against ‘the victim of domestic abuse.’”

28, 2018) and appeal dismissed (Minn. June 5, 2019); ( reasoning that the limited nature of the complainant’s testimony minimized the potential for unfair prejudice , the district court’s final jury instruction s alleviated much of the risk that the jury would improperly convict the defendant for the prior offenses rather than the charged offe

review denied (Minn. Oct.

looking for shotgun) ; State v. Mullen , ( underlying conduct included the defendant breaking victim’s window and threatening to kill her); State v. Stillday , (underly ing conduct included evidence that defendant punched victim in the face several times and caused the victim to lose consciousness); State v. Barnslater , -49 (Minn. App. 2010) (underlying conduct included multiple acts of violence against victim).

review denied (Minn. Oct.

The purpose of the statute is to “demonstrate the history of the relationship between the accused and the victim.” State v. Barnslater , review denied (Minn. Oct.

State v. Barnslater , , review denied (Minn. Oct.

review denied (Minn. Oct.

The probative value of r elationship evidence depends on the extent to which the evidence “helps to establish the relationship between the victi m and the defendant” or “places the [charged offense] in context.” review denied (Minn. Oct.

Courts admit relationship evidence under section 634.20 if “(1) it demonstrates similar conduct by the accused; (2) the conduct is perpetrated against the victim of domestic abuse or against another family or household member; and (3) the probative value of the evidence is not substantially outweighed by the danger of unfair prejudice.”

See State v. Barnslater , , 654 (Minn. App. 2010) (stating that "[i]n light of [its] decisions in Word and Meldrum , the district court's error in failing to instruct the jury regarding the proper use of [634.20] evidence was plain" but concluding that this error did not affect the defendant's substantial rights), rev. denied (Minn. Oct.

review denied (Minn. Oct.

Then, in State v. Barnslater, we held that “[i]n light of our decisions 13 in Word and Meldrum, the district court’s error in failing to instruct the jury regarding the proper use of relationship evidence was plain.” review denied (Minn. Oct.

Id.; State v. Barnslater , 2 (Minn. App. 2010), review denied (Minn. Oct.

State v. Barnslater , -54 (Minn. App. 2010), review denied (Minn. Oct.

(concluding that relationship evidence was probative because it explained the history of the relationship 5 between the abuser and the victim); see also State v. Barnslater , (explaining that rel ationship evidence was “particularly probative” because it “place[d] the event in context” by “help[ing] to establish the relationship between the victim and the defendant”), review denied (Minn. Oct.

“Evidence presented under section 634.20 is offered to demonstrate the history of the relationship between the accused and the victim of domestic abuse.” review denied (Minn. Oct.

(deeming that the district court’s error in failing to instruct the jury regarding the proper use of the relationship evidence was plain).

Humphrey relies on three cases to support his argument that the district court erred; see McCoy, d at 161; State v. Barnslater , and State v. Word , (M inn.

“Plain error exists when the district court commits an obvious 9 error that affects the defendant ’s substantial rights.” State v. Barnslater , (citing State v. Ihle , ), review denied (Minn. Oct.

review denied (Minn. Oct.

See State v. Barnslater , n.3 (Minn. App. 2010) (concluding that an analysis under Minn. R. Evid.

“Plain error exists when the district court commits an obvious error that affects the defendant’s substantial rights.” State v. Barnslater , review denied (Minn. Oct.

State v. Barnslater , review denied (Minn. Oct.

review denied (Minn. Oct.

-54 (Minn. App. 2010), review denied (Minn. Oct.

“Evidence that helps to establish the relationship between the victim and the defendant or which places the event in context bolsters its probative value.” (quotation omitted), review denied (Minn. Oct.

“Evidence that helps to establish the relationship between the victim and the defendant or which places the event in context bolsters its probative value.” (quotation omitted), review denied (Minn. Oct.

Section 634.20 applies only in domestic-violence cases, review denied (Minn. Oct.

review denied (Minn. Oct.

review denied (Minn. Oct.