Cited by
Opinions in Minnesota that cite State of Minnesota v. Neal Curtis Zumberge, 888 N.W.2d 688.
- State of Minnesota v. Paul Armando Orocio Minn. Ct. App. 2026
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Blue Earth County State of Minnesota v. Lee Wayne Young, Jr. Procaccini, J. Dissenting, Hudson, C.J., Thissen, J
Minn. 2026
a Rule of Evidence 403 permits the district court to exclude otherwise relevant evidence for a variety of reasons, including when such exclusion would avoid the “needless presentation of cumulative evidence.” We have said that evidence is cumulative when it “merely duplicate[s] other evidence already presented.” (explaining the same).
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State of Minnesota v. John Lee Edmondson
Minn. Ct. App. 2026
the defendant claims that the exclusion of evidence deprived him of his constitutional right to a meaningful opportunity to present a complete defense.”
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State of Minnesota v. Andrew Josef Brenner
Minn. Ct. App. 2026
“Even if an objection was made and a district court abused its discretion, [appellate courts] reverse only if the exclusion of evidence was not harmless beyond a reasonable doubt.”
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State of Minnesota v. Sergio Morocho
Minn. Ct. App. 2026
This is true even when, as is the case here, Morocho “claims that the exclusion of evidence deprived him of his constitutional right to a meaningful opportunity to present a complete defense.” d 688, 694 (Minn. 2017).
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State of Minnesota v. Shawn Michael Tillman
Minn. 2026
In Bland, a self-defense case, we held that, “when self-defense is asserted, evidence of a specific act is admissible only to show that a defendant reasonably feared great bodily harm, provided that the defendant proves that he knew of the specific act at the time of the alleged offense.” (discussing our holding in Bland).
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State of Minnesota v. Dhara Hayi Hassan
Minn. Ct. App. 2026
the defendant claims that the exclusion of evidence deprived him of his constitutional right to a meaningful opportunity to present a complete defense.”
- State of Minnesota v. Daniel Martez Walker Minn. Ct. App. 2026
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State of Minnesota v. Daniel Martez Walker
Minn. Ct. App. 2026
Appellate courts “review a district court’s evidentiary rulings for abuse of discretion, even when, as here, the defendant claims that the exclusion of evidence deprived him of his constitutional right to a meaningful opportunity to present a complete defense.”
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State of Minnesota v. Deandre Washington Leroy Craig
Minn. Ct. App. 2026
8 Appellate courts “review a district court’s evidentiary rulings for an abuse of discretion, even when, as here, the defendant claims that the exclusion of evidence deprived him of his constitutional right to a meaningful opportunity to present a complete defense.”
- State of Minnesota v. Jamison Franklin Wells Minn. Ct. App. 2025
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State of Minnesota v. James Earl Bailey
Minn. Ct. App. 2025
“We review a district court’s evidentiary rulings for abuse of discretion, even when, as here, the defendant claims that the exclusion of evidence deprived him of his constitutional right to a meaningful opportunity to present a complete defense.”
- State of Minnesota v. Bruce Edward Frye Minn. Ct. App. 2025
- State of Minnesota, Respondent, vs. James Nyonteh, Appellant Minn. 2025
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State of Minnesota, Respondent, vs. James Nyonteh, Appellant
Minn. 2025
1 (2024) (stating that a defendant “may be convicted of either the crime charged or an included offense, but not both”); (“[E]very lesser degree of murder is an included offense.”).
- State of Minnesota v. Larry Joe Foster Minn. 2025
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State of Minnesota v. Larry Joe Foster
Minn. 2025
–97 (Minn. 2017), we held that the district court did not abuse its discretion when it excluded testimony regarding the victim’s threatening behavior, character, and previous possession of a gun because the excluded evidence covered the same ground as other evidence admitted at trial.
- State of Minnesota v. Nicholas Norton Engel Minn. Ct. App. 2025
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State of Minnesota v. Nicholas Norton Engel
Minn. Ct. App. 2025
(“We review a district court’s evidentiary rulings for abuse of discretion, even when, as here, the defendant claims that the exclusion of evidence deprived him of his constitutional right to a meaningful opportunity to present a complete defense.”).
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State of Minnesota v. Eniwo Daniel Udezi
Minn. Ct. App. 2025
Appellate courts “reverse only if the exclusion of evidence was not harmless beyond a reasonable doubt.”
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State of Minnesota v. Steven Allen Hart
Minn. Ct. App. 2025
“We review a district court’s evidentiary rulings for an abuse of discretion, even when, as here, the defendant claims that the exclusion of evidence deprived him of his constitutional right to a meaningful opportunity to present a complete defense.”
- State of Minnesota v. John Joseph Hare Minn. Ct. App. 2025
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State of Minnesota v. Anthony Dimitri Limogianni
Minn. Ct. App. 2025
Under this review, appellate courts “may consider the strength of each party’s evidence.”
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State of Minnesota v. Jacob Colt Johnson
Minn. Ct. App. 2024
(“We review a district court’s evidentiary rulings for abuse of discretion, even when, as here, the defendant claims that the exclusion of evidence deprived him of his constitutional right to a meaningful opportunity to present a complete defense.”).
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State of Minnesota v. Royal Douglas Bissonette
Minn. Ct. App. 2024
Appellate courts “review a district court’s evidentiary rulings for [an] abuse of discretion, even when, as here, the defendant claims that the exclusion of evidence deprived him of his constitutional right to a meaningful opportunity to present a complete defense.”
- 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
And even if we conclude that a district court abused its discretion in its evidentiary ruling, we will “reverse only if the exclusion of evidence was not harmless beyond a reasonable doubt.”
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Alexander John Cookson v. State of Minnesota
Minn. Ct. App. 2024
But even if the exclusion of this evidence implicated Cookson’s constitutional right to present a complete defense, this court will only reverse “if the exclusion of evidence was not harmless beyond a reasonable doubt.”
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State of Minnesota v. Gilberto Dominguez-Solis
Minn. Ct. App. 2024
And “[e]ven if an objection was made and 12 a district court abused its discretion, [appellate courts] reverse only if the exclusion of evidence was not harmless beyond a reasonable doubt.” d 688, 694 (Minn. 2017).
- State of Minnesota v. Marvel Galvaston Williams Minn. Ct. App. 2024
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State of Minnesota v. Marvel Galvaston Williams
Minn. Ct. App. 2024
Finally, Williams contends that his admissions at the guilty-plea hearing provided an insufficient factual basis for third-degree depraved-mind murder because, under the caselaw, such a murder “cannot occur where the defendant’s actions were focused on a specific person.”
- State of Minnesota v. Jerry Arnold Westrom 6 N.W.3d 145 Minn. 2024
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State of Minnesota v. Jerry Arnold Westrom
6 N.W.3d 145
Minn. 2024
1 (2022), a defendant “may be convicted of either the crime charged or an included offense, but not both.” “In Minnesota, every lesser degree of murder is an included offense.” d 120, 125 (Minn. 1975).
- 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
to present a complete defense,” we reverse if the district court’s abuse of discretion “was not harmless beyond a reasonable doubt.”
- State of Minnesota v. Daryl Shannon Williams Minn. Ct. App. 2024
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State of Minnesota v. Daryl Shannon Williams
Minn. Ct. App. 2024
If a district court abuses its discretion when excluding evidence offered by the defendant, “we reverse only if the exclusion of evidence was not harmless beyond a reasonable doubt.” d 688, 694 (Minn. 2017).
- 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
“[Appellate courts] review a district court’s evidentiary rulings for abuse of discretion, even when, as here, the defendant claims that the exclusion of evidence deprived him of his constitutional right to a meaningful opportunity to present a complete defense.”
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State of Minnesota v. Elvis Joko Porte
Minn. Ct. App. 2024
the defendant claims that the exclusion of evidence deprived him of his 6 constitutional right to a meaningful opportunity to present a complete defense.”
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State of Minnesota v. Stacey Kay Johnson
Minn. Ct. App. 2023
“[Appellate courts] review a district court’s evidentiary rulings for abuse of discretion, even when, as here, the defendant claims that the exclusion of evidence deprived him of his constitutional right to a meaningful opportunity to present a complete defense.”
- State of Minnesota v. Larry Ray House Minn. Ct. App. 2023
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State of Minnesota v. Larry Ray House
Minn. Ct. App. 2023
The same standard of review applies when “the defendant claims that the exclusion of evidence deprived him of his constitutional right to a meaningful opportunity to present a complete defense.”
- State of Minnesota v. Curtis Dwayne Thurston Minn. Ct. App. 2023
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State of Minnesota v. Curtis Dwayne Thurston
Minn. Ct. App. 2023
of abuse to “distract from his own wrongdoing[.]” As noted above, “[w]e review a district court’s evidentiary rulings for abuse of discretion, even when, as here, the defendant claims that the exclusion of evidence deprived 14 him of his constitutional right to a meaningful opportunity to present a complete defense.”
- Dakota County Anderson, J. ConState of Minnesota v. Gabriel Alfonso Sanchez Cruz Minn. 2023
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Dakota County Anderson, J. ConState of Minnesota v. Gabriel Alfonso Sanchez Cruz
Minn. 2023
1 (2022), a defendant “may be convicted of either the crime charged or an included offense, but not both.” We have recognized that “every lesser degree of murder is an included offense.”
- 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
And we will reverse a district court’s ruling “only if the exclusion of evidence was not harmless beyond a reasonable doubt.”
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State of Minnesota v. Michael James Lovestrand
Minn. Ct. App. 2023
An appellate court will reverse an evidentiary ruling “only if the exclusion of evidence was not har mless beyond a reasonable doubt.” d 688, 694 (Minn. 2017).