Cited by

(holding that recorded messages were not needlessly cumulative even when witnesses could testify as to their contents because such testimony would not capture the tone of voice), rev. denied (Minn. Nov.

-38 (Minn. App. 2010), rev. denied (Minn. Nov.

“Eliciting an officer’s testimony that [the officer] knows the defendant from prior contacts is error if the defendant’s identity is not an issue in the case.” (citation omitted), rev. denied (Minn. Nov.

See, (“[T]he rationale for admitting relationship evidence under section 634.20 is to illuminate the relationship between the defendant and the alleged victim and to put the alleged crime into the context of that relationship.”), rev. denied (Minn. Nov.

le unless the probative value is substantially outweighed by the danger of unfair prejudice, confusion of the issue, or misleading the jury, or by considerations of undue delay, waste of time, or needless presentation of cumulative evidence.” (Emphasis added.)2 Although King correctly identifies the rationale for admitting relationship evidence under section 634.20, (citing McCoy, d at 159) (“[T]he rationale for admitting relationship evidence under section 634.20 is to illuminate the relationsh

To show that the alleged misconduct did not affect the appellant’s substantial rights, “the state must prove ‘that there is no reasonable likelihood 9 that the absence of the misconduct in question would have had a significant effect on the verdict.’” (quoting Ramey, d at 302), rev. denied (Minn. Nov.

“[T]he rationale for admitting relationship evidence under section 634.20 is to illuminate the relationship between the defendant and the alleged victim and to put the alleged crime in the context of that relationship.” rev. denied (Minn. Nov.

And evidence showing “how a defendant treats his family or household members, such as his former spouses or other girlfriends,” is relevant because it “suggests how the defendant may interact with the victim.” , rev. denied (Minn. Nov.

(noting that “evidence showing how a defendant treats his family or household members” is probative to “shed[ ] light on how the defendant interacts with those close to him, which in turn suggests how the defendant may interact with the victim”), rev. denied (Minn. Nov.

is admissible unless the probative value is substantially outweighed by the danger of unfair prejudice.” The underlying rationale for admitting relationship evidence “is to illuminate the relationship between the defendant and the alleged victim and to put the alleged crime in the context of that relationship.” rev. denied (Minn. Nov.

8 “[T]he rationale for admitting relationship evidence under section 634.20 is to illuminate the relationship between the defendant and the alleged victim and to put the alleged crime in the context of that relationship.” rev. denied (Minn. Nov.

“Eliciting an officer’s testimony that he knows the defendant from prior contacts is error if the defendant’s identity is not an issue in the case.” d 630, 641 (Minn. App. 2010).

-38 (Minn. App. 2010), rev. denied (Minn. Nov.

(holding that “eliciting an officer’s testimony that he knows the defendant from prior context is error” if “identity is not an issue in the case”).

In short, the evidence of Blackwell’s guilt was “overwhelming.” rev. denied (Minn. Nov.

But it is also highly probative, because “evidence showing how a defendant treats his family or household members” is probative to “shed[] light on how the defendant interacts with those close to him, which in turn suggests how the defendant may interact with the victim.” rev. denied (Minn. Nov.

” rev. denied (Minn. Nov.

Relationship evidence admitted under section 634.20 can “illuminate the relationship between the defendant and the alleged victim and to put the alleged crime in the context of that relationship.” d 630, 637 (Minn. App. 2010), rev. denied (Minn. Nov.

29, 2008); (reasoning that a defendant’s treatment 10 of his family is probative of how a defendant interacts with those close to him, including the victim), rev. denied (Minn. Nov.

(concluding that recordings of telephone calls that the complainant had made were not “unduly cumulative” and did “not duplicate other evidence” because “[t]he recorded messages include[d] the tone of [the complainant’s] voice, which [could not] be fully reproduced by asking witnesses questions a

“[E]vidence showing how a defendant treats his family or household members” is probative to “shed[] light on how the defendant interacts with those close to him, which in turn suggests how the defendant may interact with the victim.” rev. denied (Minn. Nov.

“Eliciting an officer’s testimony that [they] know[] the defendant from prior contacts is error if the defendant’s identity is not an issue in the case.” rev. denied (Minn. Nov.

In State v. Valentine, we stated, “Obviously, evidence showing how a defendant treats his family or household members, such as his former spouses or other girlfriends, sheds light on how the defendant interacts with those close to him, which in turn suggests how the defendant may interact with the victim.” rev. denied (Minn. Nov.

27, 2010) ; d 630, 637 (Minn. App. 2010) (noting that section 634.20 evidence helps “to put the alleged crime in the context of that relationship”), rev. denied (Minn. Nov.

Evidence admitted under section 634.20 is often called “relationship evidence.” rev. denied (Minn. Nov.

(citation omitted), rev. denied (Minn. Nov.

(holding that, in trial for domestic assault of one girlfriend, evidence about appellant’s abuse of his other girlfriend was admissible as relationship evidence), rev. denied (Minn. Nov.

sheds light on how the defendant interacts with those close to him, which in turn suggests how the defendant may interact with the victim.’” -30 (Minn. App. 2014) ( rev. denied (Minn. Nov.

In State v. Valentine, this court held that “admission of the officer’s testimony that he knew [the appellant] from prior contacts was error because appellant’s identity was not at issue in the case.” rev. denied (Minn. Nov.

and recanted statements she made to the police and the district court regarding [the] abuse.”); (stating that the “state may elicit expert testimony about battered-woman syndrome to explain a victim’s counterintuitive behavior and exculpatory account of an incident” if the testimony is limited to a description of “the syndrome and its characteristics,” and the expert does not opine abo

[and] sheds light on how the defendant interacts with those close to him, which in turn suggests how the defendant may interact with the victim.”

6 in the context of that relationship.” rev. denied (Minn. Nov.

The purpose of admitting relationship evidence “is to illuminate the relationship between the defenda nt and the alleged victim and to put the alleged crime in the context of that relationship.” rev. denied (Minn. Nov.

sheds light on how the defendant interacts with those close to him, which in turn suggests how the defendant may interact with the victim.”

“[T]he rationale for admitting relationship evidence under section 634.20 is to illuminate the relationship between the defendant and the alleged victim and to put the alleged cr ime in the context of that relationship.” rev. denied (Minn. Nov.

sheds light on how the defendant interacts with those close to him, which in turn suggests how the defendant may interact with the victim.” State v. Valentine , review denied (Minn. Nov.

sheds light on how the defendant interacts with those close to him, which in turn suggests how the defendant may interact with the victim.” review denied (Minn. Nov.

See State v. Valentine , (determining that an officer’s bachelor’s degree in criminal justice, years on the job, and training sessions qualified her as an expert on domestic violence).