Cited by
Opinions in Minnesota that cite State v. Scruggs, 822 N.W.2d 631.
- State of Minnesota v. Cristian Joel Mungia Figueroa Minn. Ct. App. 2026
- State of Minnesota v. Dalvin Jarrell Crockett Minn. Ct. App. 2026
-
State of Minnesota v. Dalvin Jarrell Crockett
Minn. Ct. App. 2026
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).
-
State of Minnesota v. Jamaal Terrance Tanna
Minn. Ct. App. 2025
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).
-
State of Minnesota v. Kyle Jacob Kocurek
Minn. Ct. App. 2025
(noting plain-error analysis).
-
State of Minnesota v. Christopher Nicholas Markgraf
Minn. Ct. App. 2024
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.”
-
State of Minnesota v. Fortino Zarate
Minn. Ct. App. 2024
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).
-
State of Minnesota v. Paul Scott Seeman
Minn. Ct. App. 2024
(noting that an officer expressly informing suspect they are not under arrest is factor indicating that suspect is not in custody).
- State of Minnesota v. Charlene Marie Waldron Minn. Ct. App. 2023
- State of Minnesota v. Charlene Marie Waldron Minn. Ct. App. 2023
-
State of Minnesota v. Lorenzo Thomas Sims
Minn. Ct. App. 2023
(stating that rule 404(b) “sets forth the requirements for admissibility of Spreigl evidence”); (acknowledging the dangers inherent in evidence of prior offenses).
-
State of Minnesota v. Frank James Bigbear
Minn. Ct. App. 2023
(noting that credibility determinations are the exclusive province of the jury).
-
State of Minnesota v. Gordy Lee Burkhart
Minn. Ct. App. 2023
Such evidence, however, may be admissible for other purposes, including “to explain a witness’s prior inconsistent statements.”
-
State of Minnesota v. Mark Scott Hendrickson
Minn. Ct. App. 2023
“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).
-
State of Minnesota v. Marcelo Mendez Zepeta
Minn. Ct. App. 2022
(noting that credibility determinations are the exclusive province of the jury).
-
State of Minnesota v. Michael Douglas Capshaw
Minn. Ct. App. 2022
(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) ).
-
State of Minnesota v. Jeremy Jantile Burton
Minn. Ct. App. 2022
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).
-
Anthony Emerson Howson v. State of Minnesota
Minn. Ct. App. 2022
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).
- State of Minnesota v. Bounkieng Sinthavong Minn. Ct. App. 2022
-
State of Minnesota v. Kayla Catelyn Waltz
Minn. Ct. App. 2022
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)
-
State of Minnesota v. Shawn Douglas Hager
Minn. Ct. App. 2022
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 , ().
-
State of Minnesota v. Clifford Lamont Lea
Minn. Ct. App. 2021
(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).
-
State of Minnesota v. Gary Christopher Petersen
Minn. Ct. App. 2020
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).
- State of Minnesota v. Christopher Edward Coleman Minn. Ct. App. 2020
-
St. Louis County Thissen, J. Took no part, Moore, J. State of Minnesota,
Minn. 2020
(citation omitted) (internal quotation marks omitted).
-
State of Minnesota v. Gregorio Zuniga-Vallejo
Minn. Ct. App. 2019
“[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. Zinski 927 N.W.2d 272 Minn. 2019
-
State v. Zinski
927 N.W.2d 272
Minn. 2019
" State v. Watkins , , 28 (Minn. 2013) (quoting State v. Scruggs , , 642 (Minn. 2012) ).
-
State of Minnesota v. Victor Wayne Lynch
Minn. Ct. App. 2019
The supreme court has distinguished between “playing a knowing role in the crime” and “mere presence at the scene.” d 631, 640 (Minn. 2012).
-
State of Minnesota v. Spencer Charles Nichols
Minn. Ct. App. 2018
“[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.”
-
State of Minnesota v. Adam Gregory Behl
Minn. Ct. App. 2018
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.”
-
State of Minnesota v. Shane Lester Gullickson
Minn. Ct. App. 2018
This court “review[s] a district court ’s refusal to give a requested jury instruction for abuse of discretion.”
- State v. Longo 909 N.W.2d 599 Minn. Ct. App. 2018
-
State v. Longo
909 N.W.2d 599
Minn. Ct. App. 2018
State v. Scruggs , , 642 (Minn. 2012) (quotation omitted).
-
State of Minnesota v. Tyler Manfred Lukat
Minn. Ct. App. 2018
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).
-
In the Matter of the Welfare of: C. W. A., Child
Minn. Ct. App. 2017
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
-
State of Minnesota v. Zane Robert Stigen
Minn. Ct. App. 2017
See State v. Scruggs , -51 (Minn. App. 2008), review denied (Minn. Sept.
-
State of Minnesota v. Sean Fitzgerald Pozzi
Minn. Ct. App. 2017
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).
-
State of Minnesota v. Javaris Martin
Minn. Ct. App. 2017
See, e.g., State v. Scruggs , (M inn.
- State of Minnesota v. Robert Todd Ferguson Minn. Ct. App. 2017
-
State of Minnesota v. Robert Todd Ferguson
Minn. Ct. App. 2017
(providing that a witness is an accomplice if the witness could have been charged and convicted of the same crime as the defendant).
- State of Minnesota v. Tracee Chung Minn. Ct. App. 2016
-
State of Minnesota v. Tracee Chung
Minn. Ct. App. 2016
(“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
- State of Minnesota v. Jose Martin Lugo, Jr. 887 N.W.2d 476 Minn. 2016
-
State of Minnesota v. Jose Martin Lugo, Jr.
887 N.W.2d 476
Minn. 2016
-68 (Minn.2013); -95 (Minn.2006)
- State of Minnesota v. Patrick Allison Baker Minn. Ct. App. 2016
- State of Minnesota v. Patrick Allison Baker Minn. Ct. App. 2016
- State of Minnesota v. Troy Gary Benjamin Minn. Ct. App. 2016
-
State of Minnesota v. Troy Gary Benjamin
Minn. Ct. App. 2016
(citations and quotation omitted).
- State of Minnesota v. Bradley Dean Johnson Minn. Ct. App. 2016