Cited by

-42 (Minn. 2015) (stating that, when determining whether relationship evidence significantly affected the verdict, an appellate court considers the district court’s cautionary instruction and presumes that the jury followed said instruction); see also Taylor, d at 207 (“We presume that the jury follo

A. Under the invited-error doctrine, a party is estopped from “assert[ing] on appeal an error that [the party] invited or that could have been prevented at the district court.” d 79, 94 (Minn. 2024) (“We have recognized that the doctrine of invited error prevents a party from challenging on appeal a district court decision to which the party consented or affirmatively requested.”); n.10 (Minn.

“[C]autionary instructions ‘lessen[] the probability of undue weight being given by the jury to the evidence.’” Lindsey, d at 757 (); (stating that the potential for unfair prejudice from relationship evidence may be lessened by the district court providing a cautionary instruction to the jury).

Further, we have repeatedly concluded that “[t]he likelihood of unfair prejudice from relationship evidence may be lessened by making a cautionary instruction to the jury.” Boswell, d at 653 (); -42 (Minn. App. 2017) (observing that “cautionary instructions lessened any probability that the jury would rely improperly on relationship evidence”).

Further, a cautionary instruction can reduce “the probability of undue weight being given by the jury to the evidence.” (quotation omitted) ; see also Andersen, 900 d at 441 (“[T]he district court’s cautionary instructions lessened any probability that the jury would rely improperly on relationship evidence.”).

Whether a cautionary instruction was given is one factor in assessing the impact of the evidence, and the evidence of the defendant’s guilt is another factor.

(stating that providing “numerous cautionary instructions” before introducing relationship evidence lessened likelihood of jury’s unfair prejudice).

A cautionary instruction can reduce “the probability of undue weight being given by the jury to the evidence.” (quotation omitted).

The cautionary instructions “lessened the probability of undue weight being given by the jury to the evidence.” (quotation omitted).

State v. Andersen , -42 (Minn. App. 2017).

See, (affirming admission of relationship evidence, in part, because the district court “provided numerous cautionary instructions .

A 16 cautionary instruction can reduce “the probability of undue weight being given by the jury to the evidence.” (quotation omitted).

An appellant must show that the district court erred in admitting relationship evidence and that “there is a reasonable possibility that the wrongfully admitted evidence significantly affected the verdict.” (quotation omitted).

See, (stating that the numerous cautionary instructions provided by the district court “lessened the probability of undue weight being given by the jury to the evidence”); -42 (Minn. App. 2017) (observing that the district court’s cautionary instructions “lessened

Appellate courts will not consider arguments that are “devoid of legal authority.” State v. Benton , (declining to address Benton’s claims that were unsupported by the record or citations to legal authority).

See, e.g., 10 State v. Benton , Andersen, d at 441-42.

See, (stating that appellate courts will not consider arguments that are unsupported by the record and devoid of legal authority); (deeming an issue waived because appellant failed to make and develop an argument in their brief).

mentioning it only once during closing argument ”); (determining that the admission of relationship evidence was harmless whe n the state made “sparse use of the relationship evidence in closing argument”).

See, 542 (Minn. 2015) (affirming the admission of the defendant’s acts of domestic abuse against his sister and ex-girlfriend as relationship evidence even though the acts occurred six or seven years earlier); 730 (Minn. App. 2014) (affirming the admission of the defendant’s act

(explaining that the prosecutor’s sparse use of relationship evidence was not prejudicial to the defendant); see also Hall, d at 842 (stating that an appellate court considers whether the testimony was highly persuasive, if the evidence was used in closing argument, and the defense’s abi

(stating that pro se argument was meritless because it was unsupported by the record and devoid of legal authority); (stating that reviewing court may decline to address pro se claims that lack argument and citation to legal authority or the recor

does not require us to turn a blind eye to errors that seriously 8 affect the fairness, integrity or public reputation of judicial proceedings .” .

at *7-9 (citing State v. Benton , -41 (Minn. 2015), and Weaver v. Massachusetts, 137 S. Ct. 1899, 1907-08, 1910, 19 12 (2017)).

(stating that the district co urt’s use of 11 cautionary instructions regarding the proper use of relationship evidence under Minn. Stat. § 634.20 lessened the probability that the jury would give undue weight to that evidence).

al rights war rants reversal only when the error must be addressed to ensure the fairness, integrity, or public reputation of judicial proceedings); Olano, 507 U.S. at 736–37; Johnson, 520 U.S. at 470 (assessing whether reversal of the conviction would expose the judicial process to public ridicule after assuming that the defendant’s substantial rights were harmed ); 0–41 (Minn. 2015) (noting that the judi cial process would be “thwarted” if the defendant who requested the courtroom closure coul

Compare State v. Benton , -41 (Minn. 2015) (concluding any error in closing courtroom was invited by defen dant and did not seriously affect fairness, integrity, or reputation of judicial proceedings), with State v. Brown , (“Structural errors always invalidate a conviction whether or not a timely obje

Maine, 2020 WL 3042248, at *8-9 ( (applying the plain error standard of review) (applying a de novo standard of review)).

[W]e have the discretionary authority to remedy errors that seriously affect the fairness, integrity or public reputation of judicial proceedings, even when the defendant invited the error.” see also Gisege, d at 158 n.5 (rejecting the state’s argument that the invited -error 11 Here, appellant argues that his right to a public trial was violated when the district court closed the courtroom for a portion of jury voir dire.

3 State v. Benton , (concl uding that pro se argument was meritless because it was unsupported by the record and devoid of legal authority).

The state, however, arguing that this case is more like Benton than to those cases in which appellate courts applied the de novo standard of review because here “the record is clear that Appellant did not make any objections to the closure .

Its purpose is to prevent defendants from raising their own trial strategy as a basis for reversal, id., and to discourage litigants from intentionally creating appealable issues, (M inn.

-41 (Minn. 2015); see also Waller , 467 U.S. 42 n.2, 104 S. Ct. at 2213 n.2 (noting that state court may determine whether defendant who consented to closure “is procedurally barred from seeking relief as a matter of state law”).

State v. Benton , , 541 (Minn. 2015) (quoting State v. Riddley , , 428 (Minn. 2009) ).

-39, 541-42 (Minn. 2015) (holding that mor e extensive relationship evidence did not significantly affect a verdict be cause the evidence was solicited from a single witness, the evidence was mentioned in the prosecutor’s closing argument “only once in passing,” and cautionary instructions we re provided).

The invited-error doctrine prov ides that “a party cannot assert on appeal an error that he invited or that could have been prevented at the district court.” (quotation omitted).

“As a general rule a party cannot assert on appeal an error that he invited or that could have been prevented at the district court.” State v. Benton , (quotation omitted).