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Downie testified that he did not obtain a search warrant before the seizure “[b]ecause the 7 data on cell phones is easily destroyable,” and that “to prevent the destruction of evidence [he] seized the phone.” the district court denied LaFlex’s motion.

Witness testimony may serve as direct evidence “when it reflects a witness’s personal observations and allows the jury to find the defendant guilty without having to draw any inferences.”

(stating witness testimony serves as direct evidence); d 29, 40 (Minn. 2024) (stating that video recordings are direct evidence of “what they show”).

-40 (Minn. 2016); see also Firkus, d at 478 (discussing the standard in terms of particular elements).

Witness 6 testimony “is direct evidence when it reflects a witness’s personal observations and allows the jury to find the defendant guilty without having to draw any inferences.”

“In a criminal case, the remedy for an illegal search or seizure is generally limited to the suppression of illegally obtained evidence.” State v. Horst

(quotation omitted); (stating that appellate courts “use the same standard of review in bench trials and in jury trials in evaluating the sufficiency of the evidence”).

“With respect to the substantial-rights requirement, [the appellant] bears the burden of establishing that there is a reasonable likelihood that the absence of the error would have had a significant effect on the jury’s verdict.” (quotation omitted).

- 40 (Minn. 2016); see also Firkus, d at 478 (discussing the standard in terms of particular elements).

7 viewed in a light most favorable to the conviction, was sufficient to permit the [fact-finder] to reach the verdict that [it] did.” (); (providing that the same standard of review is applicable for assessing sufficiency of the evidence for court trials as jury trials).

-40 (Minn. 2016) (contrasting the “traditional” direct and circumstantial-evidence analyses for sufficiency of the evidence).

Direct evidence includes witness testimony “when it reflects a witness’s personal observations and allows the jury to find the defendant guilty without having to draw any inferences.”

When reviewing the sufficiency of direct evidence to prove an element of an offense, we conduct “a painstaking analysis of the record to determine whether the evidence, when viewed in a light most favorable to the conviction, was sufficient to permit the [fact-finder] to reach the verdict which they did.”

Under the direct evidence standard of review, an appellate court’s review is limited “to a painstaking analysis of the record to determine whether the evidence, when viewed in a light most favorable to the conviction, was sufficient to permit the jurors to reach the verdict [that] they did.” (quotation omitted).

“With respect to the substantial- rights requirement, [the defendant] bears the burden of establishing that there is a reasonable likelihood that the absence of the error would have had a significant effect on the jury’s verdict.” (quotation omitted); see also Griller, d at 741 (describing defendant’s burden as a “heavy” one).

Under this standard, “we limit our review to a painstaking analysis of the record to determine whether the evidence, when viewed in a light most favorable to the conviction, was sufficient to permit the [factfinder] to reach the verdict which they did.” (quotation omitted).

-40 (Minn. 2016); (defining direct evidence as “evidence that is based on personal knowledge or observation and that, if true, proves a fact without inference or presumption” (quotation omitted)).

“In general, warrantless searches and seizures are unreasonable in the absence of a legally recognized exception to the warrant requirement.”

Katz v. United States, 389 U.S. 347, 357 (1967)

(relying on statement, “I want him dead,” as direct evidence of mens rea).

Witness testimony “is direct evidence when it reflects a witness’s personal observations and allows the jury to find the defendant guilty without having to draw any inferences.”

Under the direct-evidence standard, “we limit our review to a painstaking analysis of the record to determine whether the evidence, when viewed in a light most favorable to the conviction, was sufficient to permit 7 the jurors to reach the verdict which they did.” (quotation omitted).

“[D]irect evidence is evidence that is based on personal knowledge or observation and that, if true, proves a fact without inference or presumption.” (quotation omitted); see, (stating that, for murder conviction, defendant’s statement, “‘I want him dead,’ was direct evidence of her mens rea”).

United States v. Calandra, 414 U.S. 338, 347 (1972)