Cited by

(“Existing case law plainly requires a court to obtain a renewed jury -trial waiver when the State amends its complaint to add an additional charge after the defendant has made an initial jury -trial waiver.”); (“When the State files an amended cha

“Absent such a waiver, a criminal defendant must be tried by a jury.”

Brady v. United States , 397 U.S. 742, 748, 90 S. Ct. 1463, 1469 (1970); (discussing knowing and intelligent requirements).

“[W]hen the State amends the complaint after a defendant’s ju ry-trial waiver, the district court must obtain a renewed 6 waiver of the defendant’s right to a jury trial on the newly added charge.”

Brady v. United States, 397 U.S. 742, 748, 90 S. Ct. 1463, 1469 (1970)

If these three requirements are satisfied, an appellant also must satisfy a fourth requirement, that the error “seriously affects the fairness and integrity of the judicial proceedings.” State v. Little

Even if all three elements of plain error are satisfied, an appella nt also must demonstrate that the error “seriously affects the fairness and integrity of the judicial proceedings.”

If these three requirements are satisfied, an appellant also must satisfy a fourth requirement, that the error “seriously affects the fairness and integrity of the judicial proceedings.” d 878, 884 (Minn. 2014).

Brady v. United States , 397 U.S. 742, 7 48, 90 S. Ct. 1463, 1469 (1970)

An error is clear or obvious if it contravenes case law, a rule, or a standard of conduct.” (citation and quotations omitted).

If these three requirements are satisfied, an appellant also must satisfy a fourth requirement, that the error “seriously affects the fairness and integrity of the judicial proceedings.”

Brady v. United States , 397 U.S. 742, 748, 90 S. Ct. 1463, 1469 (1970) (“Waivers of constitutional rights not only must be voluntary but must be knowing, intelligent acts done with sufficient awareness of the relevant circumstances and lik ely consequences.”)

“It is an open question in Minnesota whether unpreserved structural errors lead to the a utomatic reversal of a conviction .” n.3 (Minn. 2014) (Stras, J., concurring in part and dissenting in part) .

Structural errors have two essential characteristics: “(1) the error affects the framework within which a trial proceeds, and (2) the error’s effect on the proceedings is difficult to assess.”

“An error is prejudicial if there is a reasonable likelihood that the error had a significant effect on the proceeding.”

Even if the appellant satisfies each prong, this court will reverse only if the error “seriously affects the fairness and integrity of the judicial proceedings.”

Even if the defendant satisfies the first three prongs, we will reverse only if the error “seriously affects the fairness and integrity of the judicial proceedings.”

ain-error standard] requires that [the defendant] be given an opportunity to present his account of the facts to a jury under the proper instructions.”) Allowing Hayes’s second-degree-assault conviction to stand, whe n the jury was directed to find an element of the offense, would undermine “the public’s confidence in the fairness and integrity of judicial proceedings.” See State v. Little , (describing the fourth prong as a question of whether the conviction will adversely affect the public per

If these three requirements are satisfied, an appellant also must satisfy a fourth requirement, that the error “seriously affects the fairness and integrity of the judicial proceedings.”

In effect, the state must show that there was no “reasonable likelihood that the error had a significant effect on the proceeding.” State v. Little

State v. Little , (providing 7 that error is plain if it is clear or obvious in that “it contravenes case law, a rule, or a standard of conduct”).

Under the plain-error test, “the burden of demonstrating prejudice generally falls on the party seeking relief.” State v. Little

(“It is well settled that an appellate court may not base its decision o n matters outside the record on appeal, and that matters not produced and received in evidence below may not be considered.”) (quotation omitted).

(providing that error is plain if it is clear or obvious in that “it contravenes case law, a rule, or a standard of conduct” (quotation omitted)).

See State v. Little , -85 (Minn. 2014) (assuming without deciding that plain-error standard applied to unobjected -to-jury-trial-waiver issue and concluding that defendant prevailed under plain-error standard).

cable law, and fa il to analyze the law 1 We note that Stanke did incl ude photos of several checks in his pro se brief; however, “[i]t is well settled that an appellate court may not base its decision on matters outside the record on appeal, and that matters not prod uced and received in evidence below may not be considered.” State v. Little , (quotation omitted); see also Minn. R. Civ.

We will only correct plain error if it “seriously affects the fairness and integrity of the judicial proceedings.”

A defendant may waive this right, “but the waiver must be knowing, intelligent, and voluntary.”

Additionally, a defendant, while entitled to a jury trial, may waive his jury-trial rights, “but the waiver must be knowing, inte lligent, and voluntary.”

Minnesota courts have declined to reverse when a new trial would be “an exercise in futility and a waste of judicial resources.” (quotation omitted).

If these three requirements are satisfied, an appellant also must satisfy a fourth requirement, that the error “seriously af fects the fairness and integrity of the judicial proceedings.”

“An error is plain if it is clear and obvious at the time of appeal.”

at 365-66; -88 (Minn. 2014) (stating that on harmless-error review “the State bears the burden of showing that [constitutional] error was harmless beyond a reasonable doubt,” while on plain-error review the appellant must prove “a reasonable likelihood that the error had a significant effect on the verdict, regardless of

“An error is clear or obvious if it ‘contravenes case law, a rule, or a standard of conduct.’ ” ().

An error is clear or obvious if it contravenes case law, a rule, or a standard of conduct.” (quotations omitted).

If these three requirements are satisfied, the appellant also must satisfy a fourth requirement, that the error “seriously affects the fairness and integrity of the judicial proceedings.”

If these three requirements are satisfied, the appellant also must satisfy a fourth requirement, that the error “seriously affects the fairness and integrity of the judicial proceedings.” d 878, 884 (Minn. 2014).

If these three requirements are satisfied, an appellant also must satisfy a fourth requirement, that the error “seriously affects the fairness and integrity of the judicial proceedings.” d 878, 884 (Minn. 2014).

“An error is clear or obvious if it ‘contravenes case law, a rule, or a standard of conduct.’” ().