Cited by
Opinions in Minnesota that cite State v. Olsen, 824 N.W.2d 334.
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State of Minnesota, Respondent,
Minn. Ct. App. 2026
“An error in excluding evidence is harmless only if the reviewing court is satisfied beyond a reasonable doubt that if the evidence had been admitted and the damaging potential of the evidence fully realized, a reasonable jury would have reached the same verdict.” (quotation omitted), rev. denied (Minn. Feb.
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State of Minnesota, Respondent,
Minn. Ct. App. 2026
“An error in 14 excluding evidence is harmless only if the reviewing court is satisfied beyond a reasonable doubt that if the evidence had been admitted and the damaging potential of the evidence fully realized, a reasonable jury would have reached the same verdict.” (quotation omitted), rev. denied (Minn. Feb.
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State of Minnesota, Respondent,
Minn. Ct. App. 2025
We have observed that “the admission of evidence of a witness’s prior sexual conduct is highly prejudicial.” rev. denied (Minn. Feb.
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State of Minnesota, Respondent,
Minn. Ct. App. 2025
A district court improperly coerces a verdict when its instructions, taken as a whole, communicate to the jury “that it must reach a verdict, or that deadlock is not an option.” rev. denied (Minn. Feb.
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State of Minnesota, Respondent,
Minn. Ct. App. 2025
The absence of such an 16 imperative makes the supplemental instruction in this case different from supplemental instructions in other cases that a jury “must reach a verdict,” d 334, 337-40 (Minn. App. 2012), rev. denied (Minn. Feb.
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State of Minnesota, Respondent,
Minn. Ct. App. 2025
Excluding evidence “is harmless only if the reviewing court is satisfied beyond a reasonable doubt that if the evidence had been admitted and the damaging potential of the evidence fully realized, a reasonable jury would have reached the same verdict.” (quotation omitted), rev. denied (Minn. Feb.
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State of Minnesota, Respondent,
Minn. Ct. App. 2025
“An error in excluding evidence is harmless only if [we are] satisfied beyond a reasonable doubt that if the evidence had been admitted and the damaging potential of the evidence had been fully realized, a reasonable jury would have reached the same verdict.” (quotation omitted), rev. denied (Minn. Feb.
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State of Minnesota, Respondent,
Minn. Ct. App. 2024
And “[a]n error in excluding [defense] evidence is harmless only if the reviewing court is satisfied beyond a reasonable doubt that if the evidence had been admitted and the damaging potential of the evidence fully realized, a reasonable jury would have reached the same verdict.” (quotation omitted), rev. denied (Minn. Feb.
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State of Minnesota, Respondent,
Minn. Ct. App. 2024
“An error in excluding evidence is harmless only if the reviewing court is ‘satisfied beyond a reasonable doubt that if the evidence had been admitted and the damaging potential of the evidence fully realized, a [reasonable] jury would have reached the same verdict.’” ().
- State of Minnesota v. Jairo Missael Fernandez Sorto Minn. Ct. App. 2024
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State of Minnesota v. Jairo Missael Fernandez Sorto
Minn. Ct. App. 2024
Evidence of a victim’s previous sexual conduct is “highly prejudicial,” rev. denied (Minn. Feb.
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State of Minnesota, Respondent,
Minn. Ct. App. 2024
State v. Olsen , rev. denied (Minn. Feb.
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State of Minnesota, Respondent,
Minn. Ct. App. 2024
“An error in excluding [defense] evidence is harmless only if the reviewing court is ‘satisfied beyond a reasonable doubt that if the evidence had been admitted and the damaging potential of the evidence fully realized, a [reasonable] jury would have reached the same verdict.’” (), rev. denied (Minn. Feb.
- State of Minnesota v. Erik Everett Wenzel Minn. Ct. App. 2024
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State of Minnesota v. Erik Everett Wenzel
Minn. Ct. App. 2024
“An error in excluding evidence is harmless only if” we are “satisfied beyond a reasonable doubt that if the evidence had been admitted and the damaging potential of the evidence had been fully realized, a [reasonable] jury would have reached the same verdict.” (alteration in original) (quotation omitted), rev. denied (Minn. Feb.
- State of Minnesota v. Reginald Scott Hubbard Minn. Ct. App. 2024
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State of Minnesota v. Reginald Scott Hubbard
Minn. Ct. App. 2024
“An error in excluding [defense] evidence is harmless only if the reviewing court is satisfied beyond a reasonable doubt that if the evidence had been admitted and the damaging potential of the evidence fully realized, a reasonable jury would have reached the same verdict.” (quotation omitted), rev. denied (Minn. Feb.
- State of Minnesota v. Bryon Christopher Hultquist Minn. Ct. App. 2023
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State of Minnesota v. Bryon Christopher Hultquist
Minn. Ct. App. 2023
“[T]elling a jury that it must reach a verdict may cause jurors holding a minority viewpoint to surrender their honest beliefs in order to reach a unanimous verdict” and “is particularly coercive when delivered to a jury that is at an impasse.” rev. denied (Minn. Feb.
- State of Minnesota v. Ryan James Martens Minn. Ct. App. 2023
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State of Minnesota v. Ryan James Martens
Minn. Ct. App. 2023
(alteration in original) (), rev. denied (Minn. Feb.
- State of Minnesota, Respondent, Minn. Ct. App. 2023
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State of Minnesota, Respondent,
Minn. Ct. App. 2023
“An error in excluding [defense] evidence is harmless only if the reviewing court is ‘satisfied beyond a reasonable doubt that if the evidence had been admitted and the damaging potential of the evidence fully realized, a [reasonable] jury would have re ached the same verdict.’” (quoting State v. Post , ).
- State of Minnesota, Respondent, Minn. Ct. App. 2023
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State of Minnesota, Respondent, vs. Toman Davin Matthews, Appellant.
Minn. Ct. App. 2022
d 334, 340 (Minn. App. 2012), rev. denied (Minn. Feb.
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State of Minnesota, Respondent,
Minn. Ct. App. 2021
412(1); rev. denied (Minn. Feb.
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State of Minnesota, Respondent,
Minn. Ct. App. 2020
(holding exclusion of evidence warrants reversal only if admission of evidence would have led to a different verdict beyond a reasonable doubt), review denied (Minn. Feb.
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State of Minnesota, Appellant,
Minn. Ct. App. 2020
(admitting evidence of a victi m’s prior sexual conduct is “highly prejudicial”).
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State of Minnesota, Respondent,
Minn. Ct. App. 2019
review denied (Minn. Feb.
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State of Minnesota, Respondent,
Minn. Ct. App. 2018
In so doing, we apply a harmless-error test in wh ich “we determine first whethe r the district court erred, and if so, whether that error was harmless.” review denied (Minn. Feb.
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State of Minnesota, Respondent,
Minn. Ct. App. 2018
review denied (Minn. Feb.
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State of Minnesota, Respondent,
Minn. Ct. App. 2018
-41 (Minn. App. 2012) (holding that evidence that a victim went to a medical center for an STD test was not admissible under rule 412), review denied (Minn. Feb.
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State of Minnesota, Respondent,
Minn. Ct. App. 2017
In State v. Olsen, this court reasoned that such a charge is erroneous for two 5 reasons: it misstates the law, which clearly allows a hung jury, and it coerces a jury because such an instruction “may cause jurors holding a minority viewpoint to surrender their honest beliefs in order to reach a unanimous verdict.” review denied (Minn. Feb.
- State of Minnesota v. Osma Mardoqueo Escho Sanchez Minn. Ct. App. 2015
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State of Minnesota v. Osma Mardoqueo Escho Sanchez
Minn. Ct. App. 2015
“The right to present a defense is not unlimited; the admission of evidence of a witness’s prior sexual conduct is highly prejudicial and will not survive a rule 403 balancing test unless a special exception applies.” review denied (Minn. Feb.
- State of Minnesota v. Charles Lafond Lewis Minn. Ct. App. 2014
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State of Minnesota v. Charles Lafond Lewis
Minn. Ct. App. 2014
The Martin “decision established two clear rules – that it is error to charge the jury that the case must be decided, and that it is error to give an instruction that specifically encourages the minority to reconsider its position without encouraging the same of the majority.” (citing Martin, 297 Minn. at 368–69, 370, 372–73, d at 770, 772–73), review denied (Minn. Feb.
- State of Minnesota v. Enamidem Celestine Okon Minn. Ct. App. 2014
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State of Minnesota v. Enamidem Celestine Okon
Minn. Ct. App. 2014
“The right to present a defense is not unlimited; the admission of evidence of a witness’s prior sexual conduct is highly prejudicial and will not survive a rule 403 balancing test unless a special exception applies.” (quotations and citations omitted), review 6 denied (Minn. 27 Feb.
- State of Minnesota v. Javier Zapien-Arreola Minn. Ct. App. 2014
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State of Minnesota v. Javier Zapien-Arreola
Minn. Ct. App. 2014
y otherwise would likely infer that the defendant was the source of the knowledge.” (“In certain cases the due process clause, the right to confront accusers, or the right to present evidence will require admission of evidence otherwise excluded by the rape shield law.”); (“[E]vidence [of a victim’s prior sexual conduct] is .