Cited by
Opinions in Minnesota that cite State of Minnesota v. Josue Robles Fraga, 864 N.W.2d 615.
- State of Minnesota v. Larondo Connell Willis Minn. Ct. App. 2026
- State of Minnesota, Respondent, Minn. Ct. App. 2026
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State of Minnesota, Respondent,
Minn. Ct. App. 2026
“d 615, 627 (Minn. 2015), [the Minnesota Supreme Court] explicitly extended that adoption to the amended version of Minn. Stat. § 634.20.” Zinski, d at 274 n.4.
- State of Minnesota v. Daniel Martez Walker Minn. Ct. App. 2026
- State of Minnesota v. Daniel Martez Walker Minn. Ct. App. 2026
- Inquiry into the Conduct of the Honorable John P. Dehen Minn. 2025
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Inquiry into the Conduct of the Honorable John P. Dehen
Minn. 2025
dice has affected a judge’s performance of their duties in violation of Rule 2.3(A), CJC, we take instruction from decisions assessing bias in other contexts, including decisions assessing whether alleged bias by the judge requires reversal of a criminal conviction, see, e.g., Liteky v. United States, 510 U.S. 540, 555 (1994); whether a juror expressed actual bias, see, and whether recusal or removal of a judge is appropriate.
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State of Minnesota, Respondent,
Minn. Ct. App. 2025
rt’s determination of juror impartiality is especially deferential” because “a distri ct court is best positioned to judge a juror’s demeanor, as opposed to an appellate court’s review of a cold record.” Ulrich, d at 6-7 (quotation omitted).3 “The United States Constitution and the Minnesota Constitution guarantee a criminal defendant the right to an impartial jury.” U.S. Const. amend.
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State of Minnesota, Respondent,
Minn. Ct. App. 2025
The Minnesota Supreme Court has adopted Minnesota Statutes section 634.20 as a rule of evidence to allow for “the admission of evidence of similar conduct by the accused against the alleged victim of domestic abuse.” -61 (Minn. 2004)
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State of Minnesota, Respondent,
Minn. Ct. App. 2025
Appellate courts “review a district court’s decision to seat a juror for abuse of discretion.”
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State of Minnesota, Respondent,
Minn. Ct. App. 2024
Since the amendment, the supreme court has noted that “evidence of domestic conduct by the accused against family or household members other than the victim may be admitted pursuant to [section] 634.20.”
- State of Minnesota, Respondent, Minn. Ct. App. 2024
- State of Minnesota, Respondent, Minn. Ct. App. 2024
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State of Minnesota, Respondent,
Minn. Ct. App. 2024
A juror is rehabilitated “if he or she states unequivocally that he or she will follow the district court’s instructions and will set aside any preconceived notions and fairly evaluate the evidence.” d 615, 623 (Minn. 2015) (quotation omitted).
- State of Minnesota v. Gregory Paul Ulrich Minn. 2024
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State of Minnesota v. Gregory Paul Ulrich
Minn. 2024
If, however, we conclude that the district court abused 8 its discretion in denying a motion to remove a juror for cause and the biased juror “actually sits in judgment of the defendant, any conviction must be reversed.”
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State of Minnesota, Respondent,
Minn. Ct. App. 2023
Instead, “[t]o prove actual bias, the challenging party must show that the [fact -finder] exhibited strong and deep impressions that would prevent [it] from lay[ing] aside [its] impression or opinion and render[ing] a verdict based on the evidence presented in court.” d 615, 623 (Minn. 2015) (quotations omitted).
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State of Minnesota, Respondent,
Minn. Ct. App. 2023
The bias of even a single juror violates a defendant’s constitutional rights because “the impartiality of the adjudicator goes to the very integrity of the legal system.” (quotation omitted).
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State of Minnesota, Respondent,
Minn. Ct. App. 2023
(concluding that Minn. R. Civ.
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State of Minnesota,
Minn. 2023
Instead, “[t]o prove actual bias, the challenging party must show that the [fact -finder] exhibited strong and deep impressions that would prevent [it] from lay[ing] aside [its] impression or opinion and render[ing] a verdict based on the evidence presented in court.” (fourth and sixth alteration in original) (internal quotation marks omitted) (citations omitted).
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State of Minnesota, Respondent,
Minn. Ct. App. 2023
Such relationship evidence is generally admissible “unless the probative value is substantially outweighed by the danger of unfair prejudice, confusion of the issue, or misleading the jury.” Minn. Stat. § 634.20; d 153, 156 n.1 (Minn. 2004); (adopting the statute as a rule of evidence).
- Alexander James Ray, petitioner, Appellant, Minn. Ct. App. 2022
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State of Minnesota, Respondent,
Minn. Ct. App. 2022
inst the victim of domestic conduct, or against other family or household members” to be admitted “unless the probative value is substantially outweighed by the danger of unfair prejudice, confusion of the issue, or misleading the jury, or by considerations of undue delay, waste of time, or needless presentation of cumulative evidence.” Minn. Stat. § 634.20 (2020); (adopting statute as a rule of evidence).
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State of Minnesota, Respondent,
Minn. Ct. App. 2022
5 jury, or considerations of undue delay, waste of time, or needless presentation of cumulative evidence.” Id.; (adopting the statute as a rule of evidence).
- State of Minnesota, Respondent, Minn. Ct. App. 2022
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State of Minnesota, Respondent, vs. Toman Davin Matthews, Appellant.
Minn. Ct. App. 2022
Minn. Stat. § 634.20 (2020); -27 (Minn. 2015); -21 (Minn. App. 2008), ajf'd, d 883 (Minn. 2009).
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State of Minnesota, Respondent,
Minn. Ct. App. 2021
4 The supreme court later clarified “that ev idence of domestic co nduct by the accused against family or household members other than the victim may be admitted pursuant to Minn. Stat. § 634.20.” State v. Fraga , (emphasis added).
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State of Minnesota, Respondent,
Minn. Ct. App. 2021
404(b)(1) prov ides that evidence of a defendant’s prior “crime, wrong, or act is not admissible to prove the character of a person in order to show action in conformity therewith.” But “evidence of domestic conduct by the accused against family or household members other than the victim ma y be admitted pursuant to Minn. Stat. § 634.20.”
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State of Minnesota, Respondent,
Minn. Ct. App. 2021
“[E]vidence of domestic conduct by the ac cused against family or household members other than the victim may be admitted pursuant to Minn. Stat. § 634.20, which, as a matter of comity, we adopt as a rule of evidence.”
- State of Minnesota, Respondent, Minn. Ct. App. 2021
- State of Minnesota, Respondent, Minn. Ct. App. 2021
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State of Minnesota, Respondent,
Minn. Ct. App. 2021
“The bias of a single juror violates the defendant’s right to a fair trial, 3 because the impartiality of the adjudicator goes to the very integrity of the legal system.” State v. Fraga , (quotation omitted).
- State of Minnesota, Respondent, Minn. Ct. App. 2021
- State of Minnesota, Respondent, Minn. Ct. App. 2021
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State of Minnesota, Respondent,
Minn. Ct. App. 2020
“The United States Constitution and the Minnesota Constitution guarantee a criminal defendant the right to an impartial j ury.”
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State of Minnesota, Respondent,
Minn. Ct. App. 2020
(quotation and citation omitted).
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State of Minnesota, Respondent,
Minn. Ct. App. 2020
d 615, 625-26 (Minn. 2015).
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State of Minnesota, Respondent,
Minn. Ct. App. 2020
see also State v. Fraga , -27 (Minn. 2015) (recognizing that McCoy adopted section 634.20 as rule of evidence that includes evidence of domestic conduct by the accused against family or household members other than the victim).
- State of Minnesota, Respondent, Minn. Ct. App. 2020
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State of Minnesota, Respondent,
Minn. Ct. App. 2020
18, 1987); (“Fraga’s third issue, that the district cour t erred in denying his motion for a change of venue, is now moot because the conviction is reversed.”).
- State of Minnesota, Respondent, Minn. Ct. App. 2020
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State of Minnesota, Respondent,
Minn. Ct. App. 2019
Minn. Stat. § 634.20 (2014); see also State v. Fraga , -27 (Minn. 2015)
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State of Minnesota, Respondent,
Minn. Ct. App. 2019
is admissible unless the probative value is substantially outweighed by the danger of 14
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State of Minnesota, Respondent,
Minn. Ct. App. 2019
“The United States Constitution and the Minnesota Constitution guarantee a criminal defendant the right to an impartial jury.”
- State v. Jaros 932 N.W.2d 466 Minn. 2019
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State v. Jaros
932 N.W.2d 466
Minn. 2019
(quoting State v. Fraga , , 623 (Minn. 2015) )).
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State of Minnesota, Respondent,
Minn. Ct. App. 2019
“To prove actual bias, the challenging party must show that the juror exhibited strong and deep impressions that would prevent her fr om laying aside her impression or opinion and rendering a verdict based on the evid ence presented in court.” (quotations omitted).
- State of Minnesota, Respondent, Minn. Ct. App. 2019
- State v. Zinski 927 N.W.2d 272 Minn. 2019
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State v. Zinski
927 N.W.2d 272
Minn. 2019
In State v. Fraga , , 627 (Minn. 2015), we explicitly extended that adoption to the amended version of Minn. Stat. § 634.20 .