Cited by
Opinions in Minnesota that cite State v. Matthews, 800 N.W.2d 629.
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State of Minnesota, Respondent,
Minn. Ct. App. 2026
We will not reverse a conviction over erroneously admitted evidence unless there is a “reasonable possibility” that this evidence “significantly affected the verdict.” (quotation omitted) .
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State of Minnesota, Respondent,
Minn. Ct. App. 2026
This is “the equivalent of a harmless error analysis.”
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State of Minnesota v. Terence Duane Maurstad
Minn. Ct. App. 2026
d 48, 59 (Minn. 2024) (concluding that defendant “did not effectively counter the inadmissible evidence” and this favored conclusion that error was not harmless); (stating that substantial-rights analysis “is the equivalent of a harmless error analysis”).
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State of Minnesota v. Adam Hassan Yusuf
Minn. Ct. App. 2026
Although harmless error and plain error are different, the substantial-rights prong of the plain-error standard “is the equivalent of a harmless error analysis.”
- State of Minnesota, Respondent, Minn. Ct. App. 2026
- State of Minnesota v. Kenneth Gale Lanham Minn. Ct. App. 2026
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State of Minnesota v. Kenneth Gale Lanham
Minn. Ct. App. 2026
For the reasons set forth above, Lanham would have satisfied the substantial-rights element because the substantial-rights analysis is “the equivalent of a harmless error analysis.”
- State of Minnesota, Respondent, Minn. Ct. App. 2026
- State of Minnesota v. Jaisden Harold-Dru Hanners Minn. Ct. App. 2026
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State of Minnesota v. Jaisden Harold-Dru Hanners
Minn. Ct. App. 2026
“A plain error affects the substantial rights of the defendant when there is a reasonable likelihood that the error substantially affected the verdict.” (quotation omitted).
- State of Minnesota v. Nicholas Lee Hill Minn. Ct. App. 2026
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State of Minnesota v. Nicholas Lee Hill
Minn. Ct. App. 2026
The district court relied on appellant’s 2 Because the third prong of the plain-error standard “is the equivalent of a harmless error analysis,” even if I applied the harmless-error standard, appellant’s argument would likewise fail.
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State of Minnesota, Respondent,
Minn. Ct. App. 2026
“A plain error affects the substantial rights of the defendant when there is a reasonable likelihood that the error substantially affected 14 the verdict.” (quotation omitted).
- In the Matter of the Welfare of: E. J. C. L., Child Minn. Ct. App. 2025
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In the Matter of the Welfare of: E. J. C. L., Child
Minn. Ct. App. 2025
“The court’s analysis under the third prong of the plain error test is the equivalent of a harmless error analysis.”
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State of Minnesota, Respondent,
Minn. Ct. App. 2025
If the error does not implicate a constitutional right, as is the case here, the harmless-error standard controls and the appellant “must prove there is a reasonable possibility that the wrongfully admitted evidence significantly affected the verdict.” (quotations omitted).
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State of Minnesota, Respondent,
Minn. Ct. App. 2025
Our analysis under this prong of the plain-error test “is the equivalent of a harmless error analysis.”
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State of Minnesota, Respondent,
Minn. Ct. App. 2025
l rights, we may consider the following factors: “(1) the manner in which the party presented the evidence, (2) whether the evidence was highly persuasive, (3) whether the party who offered the evidence used it in closing argument, and (4) whether the defense effectively countered the evidence.” d 48, 54 (Minn. 2024) (quotation omitted); see also State v. Matthews , (noting that the harmless-error analysis, which considers these factors, is “equivalent” to analysis under the third prong of the p
- State of Minnesota, Respondent, Minn. Ct. App. 2025
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State of Minnesota, Respondent,
Minn. Ct. App. 2025
2 An appellate court’s “analysis under the third prong of the plain error test is the equivalent of a harmless error analysis.”
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State of Minnesota, Respondent,
Minn. Ct. App. 2025
dence,” (B) “whether the party who offered the evidence used it in closing argument,” (C) “whether the evidence was highly persuasive,” and (D) “whether the defense effectively countered the evidence.” d 48, 54 (Minn. 12 2024) () (stating the factors for the harmless-error analysis); (noting that the harmless-error analysis is “equivalent” to analysis under the third prong of the plain-error test).
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State of Minnesota, Respondent,
Minn. Ct. App. 2025
Although harmless error and plain error are different, the substantial -rights prong of the plain -error standard “is the equivalent of a harmless error analysis.” d 629, 634 (Minn. 2011).
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State of Minnesota, Respondent,
Minn. Ct. App. 2025
A defendant’s substantial rights are affected “when there is a reasonable likelihood that the error substantially affected the verdict.” (quotation omitted).
- State of Minnesota, Respondent, Minn. Ct. App. 2025
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A24-0666
Minn. Ct. App. 2025
“[T]he third prong of the plain error standard is the equivalent of a harmless error analysis.”
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Douglas Edward Simpson, petitioner, Appellant,
Minn. Ct. App. 2025
This is “the equivalent of a harmless error analysis.”
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State of Minnesota, Respondent,
Minn. Ct. App. 2025
The substantial-rights prong of the modified plain-error test “is the equivalent of a harmless error analysis.”
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State of Minnesota, Respondent,
Minn. Ct. App. 2024
“A plain error affects the substantial rights of the defendant when there is a reasonable likelihood that the error substantially affected the verdict.” (quotation omitted).
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State of Minnesota, Respondent,
Minn. Ct. App. 2024
But “[i]f the [appellant] fails to establish that the claimed error affected his substantial rights, we need not consider the other plain error factors.”
- State of Minnesota v. Timothy Lee Heller Minn. 2024
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State of Minnesota v. Timothy Lee Heller
Minn. 2024
Admission of testimony is a reversible abuse of discretion if there is “a reasonable possibility that the wrongfully admitted evidence significantly affected the verdict.” (citation omitted) (internal quotation marks omitted).
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State of Minnesota, Respondent,
Minn. Ct. App. 2024
“The court’s analysis under the third prong of the plain error test is the equivalent of a harmless error analysis.” State v. Matthews
- State of Minnesota, Respondent, Minn. Ct. App. 2024
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State of Minnesota, Respondent,
Minn. Ct. App. 2024
In evaluating the reasonable likelihood that admission of the evidence significantly affected the verdict, appellate courts consider “(1) the manner in which the State presented the testimony, (2) whether the testi mony was highly persuasive, (3) whether the State used the testimony in closing argument, and (4) whether the defense effectively countered the testimony.” State v. Matthews
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State of Minnesota, Respondent,
Minn. Ct. App. 2024
.” n.2 (Minn. 1994) (emphasis omitted)
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State of Minnesota, Respondent,
Minn. Ct. App. 2024
d 629, 633-34 (Minn. 2011) (describing harmless -error and plain -error review); Sessions, d at 756 (applying harmless-error review to an improper jury communication).
- State of Minnesota v. Rosalio Martinez, Jr. Minn. Ct. App. 2024
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State of Minnesota v. Rosalio Martinez, Jr.
Minn. Ct. App. 2024
Such an error affected substantial rights when “there is a reasonable likelihood that the error substantially affected the verdict.”
- State of Minnesota v. Kevin Lee Anthony Minn. Ct. App. 2024
- State of Minnesota v. Kevin Lee Anthony Minn. Ct. App. 2024
- State of Minnesota v. Said Sharif Maye 6 N.W.3d 103 Minn. 2024
- State of Minnesota v. Said Sharif Maye 6 N.W.3d 103 Minn. 2024
- State of Minnesota v. Justin James Holinka Minn. Ct. App. 2024
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State of Minnesota v. Justin James Holinka
Minn. Ct. App. 2024
In evaluating the reasonable likelihood that admission of the evidence significantly affected the verdict, appellate courts consider “(1) the manner in which the State presented the testimony, (2) whether the testimony was highly persuasive, (3) whether the State used the testimony in closing argument, and (4) whether the defense effectively countered the testimony.”
- State of Minnesota v. Walter Pierre Thomas Minn. Ct. App. 2024
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State of Minnesota v. Walter Pierre Thomas
Minn. Ct. App. 2024
(“Under the harmless error standard, a defendant who alleges an error that does not implicate a constitutional right must prove there is a reasonable possibility that the wrongfully admitted evidence significantly affected the verdict.” (quotation omitted)).
- State of Minnesota, Respondent, Minn. Ct. App. 2024
- State of Minnesota v. Justin Kainoa Kaneakua Minn. Ct. App. 2023
- State of Minnesota v. Justin Kainoa Kaneakua Minn. Ct. App. 2023
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State of Minnesota, Respondent,
Minn. Ct. App. 2023
An error affects a criminal defendant’s substantial rights “if there is a reasonable likelihood that the error substantially affected the verdict.” Id.; (stating that “analysis under the third prong of the plain error test is the equivalent to a harmless error analysis”).