Cited by
Opinions in Minnesota that cite Francis v. State, 781 N.W.2d 892.
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State of Minnesota v. Miguel Angel Garcia Ortiz
Minn. Ct. App. 2026
see Andersen, d at 10 (stating that “[t]he extent of trial counsel’s investigation is considered part of trial strategy”); (stating that counsel’s decision whether to cross-examine a witness constituted trial strategy); (stating that defense counsel’s decision about what testimony to elicit from a witness on cross-examination constituted a strategic decision).
- Hennepin County State of Minnesota v. Johnny Leroy Brown Hudson, C.J. Minn. 2026
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State of Minnesota v. Daniel Alexander Albert
Minn. Ct. App. 2026
Appellate courts “generally do not review ineffective assistance of counsel claims based on trial strategy.” Francis v. State, 21
- State of Minnesota (A24-1341) (A24-1489) v. Gary Duane Egolf Jensen (A24-1341) (A24-1489) Minn. Ct. App. 2026
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State of Minnesota v. Alexander Lee Endres
Minn. Ct. App. 2026
Leake, d at 536 ; (noting that whether to call an expert witness and whether to cross-examine on a certain topic were matters of trial strategy); (holding that counsel’s decision to pursue certain evidence and not other evidence fell within the realm of defense stra
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State of Minnesota v. Brian James Krutchek
Minn. Ct. App. 2025
(concluding that whether to cross- examine the state’s expert witnesses constituted trial strategy).
- In re the Marriage of: Ryan Russell Preusse v. Amanda Jayne Preusse Minn. Ct. App. 2025
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In re the Marriage of: Ryan Russell Preusse v. Amanda Jayne Preusse
Minn. Ct. App. 2025
(stating that self-represented party who appears pro se “is held to the standard of an attorney in presenting his appeal”).
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State of Minnesota v. Charles Todd Bragg
Minn. Ct. App. 2025
Although criminal defendants enjoy the right to counsel at “critical stages of the proceedings,” (quotation omitted), the right to counsel extends only “for one review of a criminal conviction, whether by direct appeal or a first review by postconviction proceeding,” (quotations omitted).
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State of Minnesota v. Ryan Marshall McNally
Minn. Ct. App. 2024
A party that appears pro se “is held to the standard of an attorney in presenting his appeal.”
- State of Minnesota v. Casey Lee Frankl Minn. Ct. App. 2024
- State of Minnesota v. Casey Lee Frankl Minn. Ct. App. 2024
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Rosa Maria Maldonado Lopez v. Brooke Lea Simpson
Minn. Ct. App. 2023
A pro se party “is held to the standard of an attorney in presenting [an] appeal.” (stating that generally, a court will not modify ordinary rules and procedures because a pro se party lacks the skills and knowledge of an attorney).
- Megan Guetzkow, et al v. Brian John Irgens Minn. Ct. App. 2023
- Megan Guetzkow, et al v. Brian John Irgens Minn. Ct. App. 2023
- Stephen Carl Allwine, Minn. 2023
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State of Minnesota v. William Mendoza
Minn. Ct. App. 2023
denied, 142 S. Ct. 819 (2022); State v. Davis , n.10 (Minn. 2012) (noting that “decisions about which witnesses to interview are typically matters of trial strategy that we will not review”); (noting that whether to cross-examine the state’s expert witness and failure to call alibi witnesses were matters of trial strategy that could not constitute ineffective assistance of counsel); (noting that whether to cross -examine witness was a
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Kristopher Lee Roybal v. State of Minnesota
Minn. Ct. App. 2023
(stating appellate courts generally do not review issues of trial strategy and declining to review, in part, the depth of counsel’s investigation into alternative suspects); (concluding in part that whether to cross-examine an expert witness was trial strategy); (“Decisions about which witnesses to call at trial and what information to present to the jury are questions of trial strategy that lie within the disc
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State of Minnesota v. Freddy Ivan Bau Rocano
Minn. Ct. App. 2022
See, n.10 (Minn. 2012) (stating decisions about which witnesses to interview are usually matters of trial strategy that appellate courts do not review); (stating whether to cross-examine an expert witness is an issue of trial strategy).
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Marcel Moses v. State of Minnesota
Minn. Ct. App. 2022
(stating appellant failed to show counsel’s performance fell below an objective standard of reasonableness for failing to call expert witness).
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Chris Marquis McMorris v. State of Minnesota
Minn. Ct. App. 2022
(“Decisions about which witnesses to call at trial and what information to present to the jury are questions of trial 9 strategy that lie within the discretion of trial counsel.”).
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In the Matter of the Civil Commitment of: Jacquet Deon Munn
Minn. Ct. App. 2022
See Francis v. State , (declining to consider whether to cross -examine the state’s expert witnesses constitutes erroneous conduct because it relates to trial strategy).
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Larry John Laver v. Jennifer Culver
Minn. Ct. App. 2022
(A party that appears pro se “is held to the standard of an attorney in presenting his appeal.”).
- State of Minnesota v. Marcel Dylan Zephier Minn. Ct. App. 2022
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Emmanuel Jentzen v. State of Minnesota
Minn. Ct. App. 2021
1 (2018); see also Francis v. State , d 892, 896 (Minn. 2010) (recognizing that an evidentiary hearing is unnecessary “if the petitioner fails to allege facts that are suffici ent to entitle him to the relief requested”).
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State of Minnesota v. Boyd Jerome Morson, II
Minn. Ct. App. 2020
cf. United States v. Orr, 636 F.3d 944, 952 (8th Cir. 2011) (reviewing cross-examination only when it appears counsel utterly failed to “subject the prosecution’s case to .
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North Mill Equipment Finance, LLC v. Gruz Boga, LLC and Third Party Plaintiff, Petro Siruk and third party …
Minn. Ct. App. 2020
Se lf-represented litigants “are generally held to the same standards as attorneys and must comply with court rules.” Fitzgerald v. Fitzgerald , (Mi nn.
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Samuel Zean, Eunice Zean v. Mark Reveling, et al
Minn. Ct. App. 2020
“Although some accommodations may be made for pro se litigants, this court has repeatedly emphasized that pro se litigants are generally held to the same standards as attorneys and must comply with court rules.” (providing that a party that appears pro se “is held to the standard of an attorney in presenting his appeal”).
- Vollie Andre Brown, Jr. v. State of Minnesota Minn. Ct. App. 2020
- Fredrick Dewayne Hines v. State of Minnesota Minn. Ct. App. 2020
- State v. Harvey 932 N.W.2d 792 Minn. 2019
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State v. Harvey
932 N.W.2d 792
Minn. 2019
See, e.g. , State v. Mosley , , 795 (Minn. 2014) (discussing CSLI evidence but not examining whether it was admissible); Francis v. State , , 895 (Minn. 2010) (same); State v. Tran , , 543 (Minn. 2006) (same).
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Janet H. Krasner v. Gregory Hoffman, et al., Scott Neff, et al., Luke Koski, Lori Schultze, et al
Minn. Ct. App. 2018
d 892, 896 (Minn. 2010) (-73 (Minn. 1988)).
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State of Minnesota v. Kevin Mathew Erickson
Minn. Ct. App. 2018
Because a defendant bears the burden of advancing reasons to support withdrawal, Raleigh, d at 97, and because pro se litigants are generally held to the same standards as attorneys and must comp ly with all rules of procedure, these general statements fail to meet the requirements for a plea-withdrawal motion.
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State of Minnesota v. Joshua Steven Mittelsted
Minn. Ct. App. 2017
(concluding that whether 9 to cross-examine the state’s expert witnesses constitutes trial strategy); State v. Pearson
- State of Minnesota v. Derrean Darnell Hogan Minn. Ct. App. 2017
- State of Minnesota v. Derrean Darnell Hogan Minn. Ct. App. 2017
- LaQuinn Jamul Williams v. State of Minnesota Minn. Ct. App. 2016
- LaQuinn Jamul Williams v. State of Minnesota Minn. Ct. App. 2016
- Randy Leeroyal Swaney v. State of Minnesota 882 N.W.2d 207 Minn. 2016
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Randy Leeroyal Swaney v. State of Minnesota
882 N.W.2d 207
Minn. 2016
(concluding that petitioner had not shown prejudice because the desired testimony would not have refuted the substantial evidence against him).
- Izell Wright Robinson v. State of Minnesota Minn. Ct. App. 2016
- Izell Wright Robinson v. State of Minnesota Minn. Ct. App. 2016
- Troy K. Scheffler v. Commissioner of Public Safety Minn. Ct. App. 2016
- Troy K. Scheffler v. Commissioner of Public Safety Minn. Ct. App. 2016
- Shawn Michael O'Connell v. State of Minnesota 858 N.W.2d 161 Minn. Ct. App. 2015
- Shawn Michael O'Connell v. State of Minnesota 858 N.W.2d 161 Minn. Ct. App. 2015
- State of Minnesota v. Kyle Richard Dobson Minn. Ct. App. 2014
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State of Minnesota v. Kyle Richard Dobson
Minn. Ct. App. 2014
Counsel’s decisions not to request a Frye-Mack hearing and not to call the expert at trial fall squarely within “tactical decisions properly left to the discretion of trial counsel.” 8 See Nissalke, d at 111 (quotation omitted) (holding that decision not to file pretrial motion regarding evidence is trial strategy); (holding that decision whether to call expert witness is trial strategy).
- State of Minnesota v. Ahavel Abimbola Scherz Minn. Ct. App. 2014