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This aspect of the Spreigl analysis involves balancing “the relevance of the other offense[], the risk of the 11 evidence being used as propensity evidence, and the State’ s need to strengthen weak or inadequate proof in the case.” -01 (Minn. 2005) (noting that the “overarching concern” regarding Spreigl evidence is its potential use for an improper purpose, such as suggesting that the defendant has a propensity to commit crimes) .

The fact that we have recognized that evidence of criminal sexual conduct not charged may be prejudicial, as Johnson highlights, does not necessarily mean that a reference to such conduct creates the reasonable probability that the outcome of the trial would have been different but for that reference.

The district court must “balance the relevance of the other offenses, the risk of the evidence 12 being used as propensity evidence, and the State’s need to strengthen weak or inadequate proof in the case.”

Although we acknowledge that evidence of criminal sexual conduct in particular “can be highly prejudicial,” we are unconvinced that this error altered the outcome of the trial.

(determining that district court abused its discretion by admitting Spreigl evidence of defendant’s past criminal sexual conduct, but concluding that the error was harmless, in part, because district court provided the jury with limiting instructions and “jury is presumed to have followed [the]

To demonstrate prejudice, a defendant must show that “there is a reasonable possibility that the wrongfully admitted evidence significantly affected the verdict.” d 48, 54 (Minn. 2024) (citation omitted) (internal quotation marks omitted); (“To warrant a new trial, the erroneous admission of Spreigl evidence must create a reasonable possibility that the wrongfully admitted evidence significantly affected the verdict.” (citation omitted) (internal quotation marks omitted)).

d 303, 320 (Minn. 2009) (stating that juries are presumed to follow district court instructions).

As authority for his claim

In determining whether the probative value of other-acts evidence is outweighed by its potential for unfair prejudice, a district court must “balance the relevance of the other offenses, the risk of the evidence being used as propensity evidence, and the State’s need to strengthen weak or inadequate proof in the case.”

21 The Minnesota Supreme Court has explained that, to determine “whether [the] probative value [of other-acts evidence] outweighs its potential for unfair prejudice,” appellate courts “balance the relevance of the other offenses, the risk of the evidence being used as propensity evidence, and the State’s need to strengthen weak or inadequate proof in the case.”

In applying step five, the district court must “balance the relevance of the [Spreigl] offenses, the risk of the evidence being used as propensity evidence, and the State’s need to strengthen weak or inadequate proof in the case.”

To evaluate this question, “we balance the relevance of the [Spreigl evidence], the risk of the evidence being used as propensity evidence, and the [s]tate’s need to strengthen weak or inadequate proof in the case.”

on June 14, July 16, and August 2 and Exhibit 10, a screenshot of a text message of the OFP, because the exhibits were “inadmissible evidence of other crimes.”

(holding that appellant’s close-range shooting of victim in the abdomen, “a vital part of the body,” then leaving victim “lying on the ground, still alive and bleeding” was sufficient evidence to support intentional felony murder conviction).

If a district court has erroneously admitted Spreigl evidence, an appellate court “must determine whether there is a reasonable possibility that the wrongfully admitted evidence significantly affected the verdict.” Ness, d at 691; -21 (Minn. 2009).

(holding that the state needed Spreigl evidence to rebut defendant’s testimony that the charged offense was an accident).

-21 (Minn. 2009) (stating that the jury is presumed to have followed limiting instructions and concluding that the district court’s erroneous admission of evidence was not reversible error because there was no reasonable possibility that the evidence significantly affected the verdict).

One such purpose is when the other acts “were part of the immediate episode for which defendant is being tried.” -16 (Minn. 2009) (quotation omitted).

To make this determination, appellate courts “balance the relevance of the [prior] offenses, the risk of the evidence being used as propensity evidence, and the State’s need to strengthen weak or inadequate proof in the case.”

(stating that intent is “an inference drawn by the [fact -finder] from the t otality of the circumstances”).

-16 (Minn. 2009) (recognizing the admissibility of “evidence which relates to offenses that were part of the immediate episode for which [a] defendant is being tried” (quotation omitted)); d 125, 131 (Minn. App. 2009) (concluding that “a rule 404(b) analysis is unnecessary if the evi

When evaluating whether the potential for unfair prejudice outweighs the probative value of the Spreigl evidence, we must “balance the relevance of the [Spreigl evidence], the risk of the evidence being used as propensity evidence, and the [s]tate’s need to strengthen weak or inadequate proof in the case.”

(a defendant’s intent may be reasonably inferred from other facts and is usually resolved circumstantially by the fact-finder); - 26 (Minn. 1999) (the fact-finder can discern a defendant’s intent from the totality of

-16 (Minn. 2009); Spreigl, d at 173.2 In this case, however, we need not decide whether admitting the evidence was an abuse of discretion because the error, if any, was harmless.

(noting that the jury draws an inference of intent “from the totality of circumstances” (quotation omitted)).

26, 2020); (stating that juries presumably follow instructions).

26, 2020); (stating that juries presumably follow instructions).

(stating that juries presumably follow instructions); (stating that cautionary instructions reduce risk of unfair prejudice).

“Intent is generally proved by inferences drawn from a person’s words or actions in light of all the surrounding circumstances.” (quotation omitted); (noting that the jury draws an inference of intent “from the totality of circumstances” (quotations omitted)).

13 disbelieved any testimony conflicting with that verdict.” (citation omitted) (internal quotation marks omitted).

When evaluating whether the potential for unfair prejudice outweighs the probative value, appellate courts “balance the relevance of the [Spreigl evidence], the risk of the evidence being used as propensity evidence, and the State’s need to strengthen weak or inadequate proof in the case.”

When evaluating whether the potential for unfair prejudice outweighs the probative value of the evidence, appellate courts “balance the relevance of the [Spreigl evidence], the risk of the evidence being used as propensity evidence, and the State’s need to strengthen weak or inadequate proof in the case.”

Evidence of intent is typically circumstantial because “[i]ntent is generally proved by inferences drawn from a person’s words or actions in light of all the surrounding circumstances.” (quotation omitted); (noting that the jury draws an inference of intent “from the totality of the circumstances” (quotations omitted)).

26, 2020); (stating that juries presumably follow instructions).

In the context of Spreigl evidence, the district court’s erroneous admission “must create a reasonable possibility that the wrongfully admitted evidence significantly affected the verdict.” (quotation omitted).

1 Yang also states that the district court “appeared to invoke the ‘immediate episode’ doctrine of admissibility.” Th is doctrine allows admission of evidence of other offenses only where the other offenses and the charged offense are “linked together in point of time or circumstances so that one cannot be fully shown without proving the other.” (quotation omitted).

-16 (Minn. 2014) (reasoning that review is limited to the rationale cited by the district court, and not the one supplied by the state).

In applying the fifth prong of the test—whether the probative value of the evidence was outweighed by the potential for prejudice—the district court must “balance the relevance of the [other acts], the risk of the evidence being used as propensity evidence, and the State’s need to strengthen weak or inadequate proof in the case.”

See Tomlinson, d at 287-88 (noting that cautionary instructions reduce risk of unfair prejudice); (stating that juries presumably follow instructions).

-16 (Minn. 2009) (recognizing the admissibility of “evidence which relates to offenses that were part of the immediate episode for which [a] defendant is being tried” (quotation omitted)); (stating that “a rule 404(b) analysis is unnecessary if the evidenc

“To warrant a new trial, the erroneous admission of Spreigl evidence must create a reasonable possibility that the wrongfully admitted evidence significantly affected the verdict.” (quotation omitted); see also Thao, d at 839.

- 22 (Minn. 2009); (holding that firing a single shot from a pen gun at a victim who was 12 feet away was evidence of intent to kill).