Cited by
Opinions in Minnesota that cite State v. Hill, 801 N.W.2d 646.
- Samuel David Berg v. State of Minnesota Minn. Ct. App. 2026
- Samuel David Berg v. State of Minnesota Minn. Ct. App. 2026
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State of Minnesota, Respondent,
Minn. Ct. App. 2026
the credibility of the defendant is important because the jury must often decide between competing accounts of the events leading up to the crime.”
- State of Minnesota v. Nicholas James Firkus Minn. 2026
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State of Minnesota v. Nicholas James Firkus
Minn. 2026
See, 656 (Minn. 2011) (concluding that the bullet trajectory and wounds contradicted the defendant’s claim that the victim was standing and facing him at the time of the shooting); (concluding that bullet trajectory and wounds were consistent with the eyewitness test
- State of Minnesota v. Shane Joseph Gross Minn. Ct. App. 2026
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State of Minnesota v. Shane Joseph Gross
Minn. Ct. App. 2026
–52 (Minn. 2023); –55 (Minn. 2011).
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State of Minnesota, Respondent,
Minn. Ct. App. 2026
We have held, in rare cases, that the cumulative effect of trial errors can deprive an appellant of their constitutional right to a fair trial when the “errors and indiscretions, none of which alone might have been enough to tip the scales, operate to the [appellant’s] prejudice by producing a biased jury.” (quotations omitted).
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State of Minnesota, Respondent,
Minn. Ct. App. 2025
The cumulative effect of errors at trial can deprive a defendant of his constitutional right to a fair trial even when the errors, “none of which alone might have been enough to tip the scales, operate to the defendant’s prejudice by producing a biased jury.”
- State of Minnesota v. John Kevin Melina Minn. Ct. App. 2024
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State of Minnesota v. John Kevin Melina
Minn. Ct. App. 2024
We review a district court’s ruling on the impeachment of a witness by prior convictions for “a clear abuse of discretion.” (quotation omitted).
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State of Minnesota, Respondent,
Minn. Ct. App. 2024
sence of the misconduct in question would have had a significant effect on the verdict of the jury,” Ramey , d at 302 (quotation omitted), we consider “(1) the strength of the evidence against the defendant ; (2) the pervasiveness of the improper conduct; and (3) whether the defendant had an opportunity (or made efforts) to rebut the prosecutor’s improper suggestions,” d 646, 654-55 (Minn. 2011).
- State of Minnesota v. Larry Ray House Minn. Ct. App. 2023
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State of Minnesota v. Larry Ray House
Minn. Ct. App. 2023
An appellate court may reverse a conviction based on cumulative trial errors if “errors and indiscretions, none of which alone might have been enough to tip the scales, operate to the defendant’s prejudice by producing a biased jury.” d 646, 659 (Minn. 2011) (quotation omitted).
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State of Minnesota, Respondent,
Minn. Ct. App. 2023
“We will not reverse a district court’s ruling on the impeachment of a witness by prior conviction absent a clear abuse of discretion.” (quotation omitted).
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State of Minnesota, Respondent,
Minn. Ct. App. 2023
In deciding whether the state has met this burden, we may consider “(1) the strength of the evidence against the defendant; (2) the pervasiveness of the improper conduct; and (3) whether the defendant had an opportunity (or made efforts) to rebut the prosecutor’s improper suggestions.” -55 (Minn. 2011).
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State of Minnesota, Respondent,
Minn. Ct. App. 2023
When deciding whether the state has met this burden, we consider “(1) the strength of the evidence against the defendant; (2) the pervasiveness of the improper conduct; and (3) whether the defendant had an opportunity (or made efforts) to rebut the prosecutor’s improper suggestions.” -55 (Minn. 2011).
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State of Minnesota, Respondent,
Minn. Ct. App. 2023
Knott finally argues that he is entitled to a new trial because the “sheer number of errors operated to [his] prejudice by producing a biased jury.” d 646, 659 (Minn. 2011) (stating that cumulative errors can “tip the scales, operate to the defendant’s prejudice by producing a biased jury” (quotation omitted)).
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State of Minnesota, Respondent,
Minn. Ct. App. 2022
When deciding whether the state has met this burden, we consider “(1) the strength of the evidence against the defendant; (2) the pervasiveness of the improper conduct; and (3) whether the defendant had an opportunity (or made efforts) to rebut the prosecutor’s improper suggestions.” -55 (Minn. 2011).
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State of Minnesota, Respondent,
Minn. Ct. App. 2022
Substantial Rights Even assuming that the prosecutor committed plain error during closing argument, we only reverse a conviction due to prosecutorial misconduct if such plain error “affects the defendant’s substantial rights.”
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In re the Marriage of: Cory Michael Bayer, petitioner, Respondent,
Minn. Ct. App. 2022
(recognizing that the district court is in a “unique position” to assess and weigh the Jones factors and “must be accorded broad discretion”), rev. granted (Minn. Apr.
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State of Minnesota, Respondent,
Minn. Ct. App. 2022
Impeachment evidence of a previous felony conviction is sanitized when it is admitted “without revealing the nature or details of the convi ction at the time of impeachment.” State v. Hill , n.1 (Minn. 2011).
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Eligio Rodriguez Cerrito, petitioner, Appellant,
Minn. Ct. App. 2022
State v. Hill , d 646, 654-55 (Minn. 2011).
- State of Minnesota, Respondent, Minn. Ct. App. 2022
- State of Minnesota, Respondent, Minn. Ct. App. 2021
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Brian Ford Dowell, petitioner, Appellant,
Minn. Ct. App. 2021
(concluding that having, but not taking, the opportunity to rebut does not affect an appellant’s substantial rights); d 35, 40 (Minn. 1994) (failing to object or seek curative instruction weighs against reversal).
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State of Minnesota, Respondent,
Minn. Ct. App. 2021
5 -52 (Minn. 2011) (quotations and citations omitted).
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State of Minnesota, Respondent,
Minn. Ct. App. 2020
State v. Hill , ; (noting that we apply an abuse-of-discretion standard of review to evidentiary rulings that invoke constitutional rights).
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State of Minnesota, Respondent,
Minn. Ct. App. 2020
d 646, 658 (Minn. 2011) (noting that parties disagreed about standard of review and applying “less onerous” harmless-error analysis); -84 (Minn. 2007) (explaining that both harmless-error and plain-error review require that, for an error to be reversible, it must affect a defend
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State of Minnesota,
Minn. 2020
“We will not reverse a district court’s ruling on the impeachment of a witness by prior conviction absent a clear abuse of discretion.” (citation omitted) (internal quotation marks omitted).
- State of Minnesota, Respondent, Minn. Ct. App. 2020
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State of Minnesota, Respondent,
Minn. Ct. App. 2020
(applying harmless-error analysis to prosecutorial misconduct); (applying modified plain-error analysis to prosecutorial misconduct).
- State of Minnesota, Respondent, Minn. Ct. App. 2020
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State of Minnesota, Respondent,
Minn. Ct. App. 2020
An appellate court “will not reverse a district court’s rulin g on the impeachment of a witness by prior conviction absent a clear abuse of discretion.” (“We must uphold the trial court’s ruling [on impeachment evidence under Rule 609] unle ss a clear abuse of discretion is shown.” (quotatio n omitted)).
- State of Minnesota, Respondent, Minn. Ct. App. 2019
- State of Minnesota, Respondent, Minn. Ct. App. 2019
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State of Minnesota, Respondent,
Minn. Ct. App. 2019
P. 31.01; see also State v. Hill, 4 (providing a court may disregard an error where it did not affect the substantial rights of a defendant and did not meaningfully affect the verdict).
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State of Minnesota, Respondent,
Minn. Ct. App. 2019
d 646, 651 (Minn. 2011).
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State of Minnesota, Respondent,
Minn. Ct. App. 2019
And the supreme court in State v. Hill explained that “it is the general lack of respect for the law, rather than the specific nature of the conviction, that informs the fact- 6 finder about a witness’s credibility.” (Mi nn.
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State of Minnesota, Respondent,
Minn. Ct. App. 2019
Appellate courts “will not reverse a district court’s ruling on the impeachment of a witness by prior conviction absent a clear abuse of discretion.” (quotation omitted).
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State of Minnesota, Respondent,
Minn. Ct. App. 2019
“[T]he decision about what details, if any, to disclose about the conviction at the time of impeachment is a decision that remains within the sound discretion of the district court.” State v. Hill
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State of Minnesota, Respondent,
Minn. Ct. App. 2019
In other words, any felony conviction is probative of a witness’s credibility.” State v. Hill
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State of Minnesota, Respondent,
Minn. Ct. App. 2019
(4) the importance of the defendant’s testimony, and (5) the centrality of the credibility issue.” ().
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State of Minnesota, Respondent,
Minn. Ct. App. 2019
(explaining that the fact that a witness has been convicted of a felony tends to prove a “genera l lack of respect for the law,” thus making that witness less credible; the court’s reasoning only makes sense if the fact of conviction tends to prove that the witness actually vio lated the law); St
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State of Minnesota, Respondent,
Minn. Ct. App. 2019
An appellate court “will not reverse a district court’s ruling on the impeachment of a witness by prior conviction absent a clear abuse of discretion.” d 646, 651 (Minn. 2011) (quotation omitted).
- State of Minnesota, Respondent, Minn. Ct. App. 2019
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State of Minnesota, Respondent,
Minn. Ct. App. 2019
” State v. Hill , (quoting State v. Jones , ).
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State of Minnesota, Respondent,
Minn. Ct. App. 2019
If a court finds that “the prejudicial effect of disclosing the nature of a felony conviction outweighs its probative value, then it may still allow a party to impeach a witness with an unspecified felony conviction if the use of the unspecified convi ction satisfies the balancing test of Rule 609(a)(1).” State v. Hill , -53 (Minn. 2011).
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State of Minnesota, Respondent,
Minn. Ct. App. 2018
-40 (Minn. 2016); -59 (Minn. 2011).
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State of Minnesota, Respondent,
Minn. Ct. App. 2018
An appellate court “will not reverse a district court’s ruling on the impeachment of a witness by prior conviction absent a clear abuse of discretion.” d 646, 651 (Minn. 2011) (quotation omitted).