Cited by

Persuasion by illegitimate means includes “leading the jury to improperly conclude that [the defendant] has a propensity to behave criminally and should now be convicted, and punished, for the charged offenses.” rev. denied (Minn. Jan.

Persuasion by illegitimate means includes “leading the jury to improperly conclude that [the defendant] has a propensity to behave criminally and should now be convicted, and punished, for the 6 charged offenses.” rev. denied (Minn. Jan.

istrict court reasoned that, even if the evidence was “severely damaging” to Wharton, the state did not seek to persuade the jury through “illegitimate means.” Persuasion by illegitimate means includes “leading the jury to improperly conclude that [the defendant] 13 has a propensity to behave criminally and should now be convicted, and punished, for the charged offenses.” rev. denied (Minn. Jan.

16, 2010); (“ Relationship evidence is character evidence 6 that may be offered to show the strained relationship between the accused and the victim .

Second, Vang argues that “[t]he relationship evidence in this case lacked any specific time frame,” rev. denied (Minn. Jan.

” State v. Hormann , , rev. denied (Minn. Jun.

An error is harmless if “there is no reasonable possibility that the wrongfully admitted evidence significantly affected the verdict.” -92 (Minn. App. 2011) (), rev denied (Minn, Jan.

Persuasion by illegitimate means includes “leading the jury to improperly conclude that [the defendant] has a propensity to behave criminally and should now be convicted, and punished, for the charged offenses.” rev. denied (Minn. Jan.

Persuasion by illegitimate means includes “leading the jury to improperly conclude that [the defendant] has a propensity to behave criminally and should now be convicted, and punished, for the charged offenses.” d 883, 891 (Minn. App. 2011), rev. denied (Minn. Jan.

Persuasion by illegitimat e means includes “leading the jury to improperly conclude that [the defendant] has a propensity to behave criminally and should now be convicted, and punished, for the 9 charged offenses.” , rev. denied (Minn. Jan.

review denied (Minn. Jan.

review denied (Minn. Jan.

State v. Bauer , 15 see also State v. Mayhorn , -85 (Minn. 2006) (determining that the district court erred in admitting strained relationship evidence because the state failed to prove the prior conflict between the relevant parties by clear and convincing evidence); -91 (Minn. App. 2011) (applying requirement of clear and convincing evidence and the 404(b) balancing test) , review denied (Minn. Jan.

State v. Hormann , , review denied (Minn. Jan.

By “general relationship evidenc e,” Alvar seems to be referring to the basis of intro ducing relationship evidence est ablished under Minnesota caselaw, “independent of Minn. Stat. § 634.20, the Spreigl/rule 404(b) process, or the immediate-episode doctrine.” See State v. Hormann , review denied (Minn. Jan.

review denied (Minn. Jan.

review denied (Minn. Jan.

review denied (Minn. Jan.

It is certainly true that evidence regarding a defendant’s prior conduct can, in some situations, pose “the risk of leading the ju ry to improperly conclude that [the defendant] has a propensity to behave criminally and should now be convicted, an d punished, for the charged offense[].” State v. Hormann , review denied (Minn. Jan.

(“Minnesota caselaw has 3 established a basis for the introduction of relationship evidence independent of Minn. Stat. § 634.20 .

Outsi de of the Minn. Stat. § 634.20 exception, “Minnesota caselaw has established a basis for the introduction of relatio nship evidence independent of Minn. Stat. § 634.20, the Spreigl/rule 404(b) process, or the immediate-episode doctrine.” State v. Hormann , review denied (Minn. Jan.

review denied (Minn. Jan.

review denied (Minn. Jan.

Persuasion by illegitimate means in cludes “leading the jury to improperly conclude that [the defendant] has a propens ity to behave criminally and should now be convicted, and punished, for the charged offenses.”

(concluding, in stalking case, that relationship evidence placed the relationship in context where “the state needed to establish that appellant had given her reason to fear [his] repeated confrontationa l and intimidating conduct”), review denied (Minn. Jan.

review denied (Minn. Jan.

review denied (Minn. Jan.

404(b) is not a condition for admissibility of evidence directly pertaini ng to the relationship history between the defendant and the victim.” (citation omitted); see also State v. Hormann , 0 (Minn. App. 2011) (stating that “Minnesota precedent [does not] require[] .

review denied (Minn. Jan.

n. Stat. § 634.20 (2014), which permits admission of evidence “of similar conduct by the accused against the victim of domestic abuse,” caselaw also establishes another, non-domestic type of relationship evidence, which can be offered to show “the strained relationship between the accused and the victim.” d 872, 880 (Minn. 2009) (quotation omitted); review denied (Minn. Jan.

d 883 (Minn. App. 2011), review denied (Minn. Jan.

Such evidence is generally admissible to illuminate the relationship between the accused and the alleged victim and provide a context with which the jury can “better judge the credibility of the principals in the relationship.” (stating that relationship evidence includes evidence of a “strained relationship” that puts the incident between the accused and the victim in context), review denied (Minn. Jan.

In a criminal case, the test to be applied is “whether, after viewing the evidence and all resulting inferences in the light most favorable to the state, the evidence is sufficient to present a fact question for the jury.” review denied (Minn. Jan.