Cited by

(determining a new trial was not required in part because 4 the state did not discuss the defendant’s failure to consent to a DNA test during either opening or closing statements); Larson, d at 33 (concluding a new trial was not required whe

The supreme court has stated that “any felony conviction is probative of a witness’s credibility, and the mere fact that a witness is a convicted felon holds impeachment value.”

This court “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).

Impeachment value of prior crime The district court found that the receiving-stolen-property convictions have “strong impeachment value.” “[A]ny felony conviction is probative of a witness’s credibility, and the mere fact that a witness is a convicted felon holds impeachment value.”

“[T]he fact that a prior conviction did not directly involve truth or falsity does not mean it has no impeachment value.” Williams, d at 518 (quotation omitted); -52 (Minn. 2011) (reaffirming application of whole-person rationale and stating that “any felony conviction is probative of a witness’s credibility”).

n.1 (Minn. 2011) (explaining a “sanitized” felony conviction refers to “the admission of evidence that a witness has committed a prior felony conviction without revealing the nature or details of the conviction at the time of impeachment”).

16 When deciding if an error would have a significant effect on the verdict of the jury we consider three factors: “(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, 655 (Minn. 2011).

“In applying plain error analysis, we will reverse trial error only if there is (1) error, (2) that is plain, and (3) the error affects the defendant’s substantial rights.”

“[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).

–58 (Minn. 2011) (applying harmless-error standard to admission of all disputed testimony, some of which was not objected to, because “applying a bifurcated standard” would be “difficult[]” and “any error by the district court did not affect [defendant]’s substantial rights under either standard”).

and the court determines that the probative value of admitting this evidence outweighs its prejudicial effect.” The supreme court has stated that “any felony conviction is probative of a witness’s credibility, and the mere fact that a witness is a convicted felon holds impeachment value.”

-53 (Minn. 2011) (holding that a party may impeach a witness with an unspecified felony conviction).

.” d 646, 651 (Minn. 2011) (quotation omitted).

We reverse “only if there is (1) error, (2) that is plain, and (3) the error affects the defendant’s substantial rights.”

(referring to the harmless-error standard as the “less onerous standard” as compared to the plain-error standard).

(4) the importance of the defendant’s testimony, and (5) the centrality of the credibility issue.’” 4 (alteration in original) (quoting Jones, d at 538).

“[I]t is the general lack of respect for the law, rather than the specific nature of the conviction, that informs the [jury] about a witness’s credibility.” (stating that felony convictions are probative of a witness’s credibility, and the fact that a witness is a convicted felon has impeachment value).