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When applying the balancing test, a district court must “balance the relevance of the bad acts, 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.” (quotation omitted).

If the first three prongs of the plain-error standard are met, a reviewing court then assesses whether reversal is required to ensure “the fairness, integrity, or public reputation of judicial proceedings.” (quotation omitted).

(noting plain-error analysis).

An error is plain if it “contravenes a rule, case law, or a standard of conduct, or when it disregards well-established and longstanding legal principles.”

An error is plain if it “contravenes a rule, case law, or a standard of conduct, or when it disregards well-established and longstanding legal principles.” (quotation omitted).

(noting that an officer expressly informing suspect they are not under arrest is factor indicating that suspect is not in custody).

(stating that rule 404(b) “sets forth the requirements for admissibility of Spreigl evidence”); (acknowledging the dangers inherent in evidence of prior offenses).

(noting that credibility determinations are the exclusive province of the jury).

Such evidence, however, may be admissible for other purposes, including “to explain a witness’s prior inconsistent statements.”

“Prior bad act evidence can be unfairly prejudicial if it is used by the jury for an improper purpose, such as proof of a defendant’s propensity to commit the charged offense or general propensity for violence.” (citing Ness, d at 685).

(noting that credibility determinations are the exclusive province of the jury).

(stating that there is no reversible error when a district court’s jury instructions “read as a whole correctly state the law in language that can be understood by the jury” (quotation omitted) ).

However, a reviewing court must “distinguish between playing a knowing role in the crime and mere presence at the scene, inaction, knowledge and passive acquiescence.” (quotation omitted).

7 The supreme court has “distinguish[ed] between playing a knowing role in the crime and mere presence at the scene, inaction, knowledge and passive acquiescence.” (quotations omitted).

or otherwise deprived of his [or her] freedom of action in any significant way,” Miranda, 384 U.S. at 444, or “if, based on all the surrounding circumstances, a reasonable person under the circumstances would believe that he or she was in police custody of the degree associated with formal arrest.” -11 (Minn. 2011) (quotation omitted)

Even if all three prongs are sa tisfied, an appellate court should grant relief only if the error “seriously affect[s] the fairness, integrity, or public reputation of judicial proceedings.” State v. Scruggs , ().

(considering the state’s need for Spreigl evidence “to strengthen weak or inadequate proof in the case” (quotation omitted)); Wermerskirchen, d at 241-42 (ratifying use of Spreigl evidence to counter a defendant’s theory of fabrication).

The supreme court has distinguished “between playing a knowing role in the crime and mere presence at the scene, inaction, knowledge and passive acquiescence.” (quotations omitted).

(citation omitted) (internal quotation marks omitted).

“[A]n interrogation is custodial if, based on all t he surrounding circumstances, a reasonable person would believe he or she was in police custody to the degree associated with formal arrest.”

" State v. Watkins , , 28 (Minn. 2013) (quoting State v. Scruggs , , 642 (Minn. 2012) ).

The supreme court has distinguished between “playing a knowing role in the crime” and “mere presence at the scene.” d 631, 640 (Minn. 2012).

“[A]n interrogation is custodial if, based on all the surrounding circumstances, a reasonable person would believe he or she was in police c ustody to the degree associated with formal arrest.”

A district court properly exercises its discretion if the jury “instructions read as a whole correctly state the law in language that can be understood by the jury.”

This court “review[s] a district court ’s refusal to give a requested jury instruction for abuse of discretion.”

State v. Scruggs , , 642 (Minn. 2012) (quotation omitted).

When determining whether the potential for unfair prejudice outweighs the probative value of Spreigl evidence, the district court balances “the relevance of the [prior convictions], the risk of the evidence being used as propensity evidence, and the State’s need to strengthen weak or inadequate proof in the case.” (quotation omitted).

See, d 799, 808 (Minn. 2013) (noting the focus of the state’s case and the evidence when viewed in context); -45 (Minn. 2012) (noting the probative value of evidence introduced to anticipate challenges to witness credibility); (noting the probative value of the evidence); (notin g the context of the evidence and the over

See State v. Scruggs , -51 (Minn. App. 2008), review denied (Minn. Sept.

Pozzi contends th at “[g]iven that the trial court did not caution the jury against using the improperly -admitted evidence for this purpose, it is reasonable to assume this evidence also substantially influenced the jury’s verdict.” Cf. State v. Scruggs , 5 (Minn. 2012) (noting that cautionary instructions reduced the risk of unfair prejudice resulting from admission of evidence regarding defendant’s prior assault convictions).

See, e.g., State v. Scruggs , (M inn.

(providing that a witness is an accomplice if the witness could have been charged and convicted of the same crime as the defendant).

(“When examining whether the probative value of Spreigl evidence outweighs its potential for unfair prejudice to a defendant, we balance the relevance of the bad acts, the risk of the evidence being used as propensity 1 Evidence of other crimes or bad acts evidence is commonly referred to as

-68 (Minn.2013); -95 (Minn.2006)

(citations and quotation omitted).

“Prior bad act evidence can be unfairly prejudicial if it is used by the jury for an improper purpose, such as proof of a defendant’s propensity to commit the charged offense.”