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Juror bias violates a defendant’ s constitutional rights because “the impartiality of the adjudicator goes to the very integrity of the legal system.” (quotation omitted).

“To remove any doubt,” in State v. Fraga, the supreme court made it clear that “evidence of domestic conduct by the accused 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.”

See State v. Fraga , , 623 (Minn. 2015) ("Permitting a biased juror to serve is structural error requiring automatic reversal.").

Likewise, “[p]ermitting a biased juror to serve is structural error requiring automatic reversal.”

A juror is rehabilitated if he or she “state s unequivocally that he or she will follow the district court’s instructions and will se t aside any preconceived notions and fairly evaluate the evidence.” State v. Fraga , (quoting Prtine, d at 310).

“The bias of a single juror violates the defendant’s right to a fair trial because the impartiality of the adjudicator goes to the very integrity of the legal system.” (quotation omitted).

McCoy, d at 161 (holding section 634.20 is a rule of evidence); (clarifying adoption of section 634.20 as a rule of evidence).

(concluding that a juror who was actually biased against Fraga was seated).

See Minn. Stat. § 634.20 (2014)

“Actual bias is a question of fact which the district court is in the best position to evaluate.” State v. Fraga , (quotation omitted).

State v. McCoy , (expressly extending the application of section 634.20 as a rule of evidence to domestic conduct against fam ily or household members).

n.1 (Minn. App. 2015), review denied (Minn. Mar.

at 42 (concluding that district court did not abuse its discretion by denying defendant’s challenge of juror for cause); −26 (Minn. 2015) ( and reversing and remanding for new trial because juror with actual bias sat on jury).

Minn. Stat. § 634.20 (2014)

“Permitting a biased juror to serve is structural error requiring automatic reversal.”

“We consider a juror to be 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.” (citations and quotation omitted).

(holding that Minn. Stat. § 634.20 is a rule of evidence); (stating “[w]e review a district court’s evidentiary ruling for an abuse of discretion.”).

A previous version of section 634.20 used the term “similar conduct” in place of “domestic conduct.” d 615, 627 n.12 (Minn. 2015).

The supreme court has noted that the 2013 amendment “did not change the underlying definition.” n.12 (Minn. 2015).

In a criminal case involving domestic violence, Minnesota law allows for the admission of evidence of other “domestic conduct” by the defendant against the same victim or “against other family or household members,” “unless the probative value is substantially outweighed by the danger of unfair prejudice.” Minn. Stat. § 634.20 (2014); (“[W]e make clear today that evidence of domestic conduct by the accused against family or household members other than the victim may be admitted pursuant to Minn

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).

The implied-bias doctrine is premised on the assumption that “certain relationships or experiences create a mindset that cannot be changed or set aside.” (quotation omitted).

Riddle alleges “implied bias.” “Implied bias is a bias that is conclusively presumed as a matter of law” and “assumes that certain relationships or experiences create a mindset that cannot be changed or set aside.” (quotations omitted).

The bias of even a single juror violates a defendant’s constitutional rights because “the impartiality of the adjudicator goes to the very integrity 7 of the legal system.” (quotation omitted).