Cited by
Opinions in Minnesota that cite In re Disciplinary Action Against Smith, 903 N.W.2d 411.
- Devin Matthew Weiland v. State of Minnesota Minn. Ct. App. 2026
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State of Minnesota v. Phia Vang
Minn. Ct. App. 2026
“Evidence is material under Brady if there is a reasonable probability that, had the evidence been disclosed to the defense, the result of the proceeding would have been different.” (quotations omitted).
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Paul Scott Seeman v. State of Minnesota
Minn. Ct. App. 2026
must meet all three requirements to establish a Brady violation.”
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State of Minnesota v. Deandre Washington Leroy Craig
Minn. Ct. App. 2026
if proven at an evidentiary hearing, must meet all three requirements to establish a Brady violation.”
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State of Minnesota v. Pharoah Gerald Ashley
Minn. Ct. App. 2025
must meet all three requirements to establish a Brady violation.”
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State of Minnesota v. Terry Izeal Heggs
Minn. Ct. App. 2025
A reasonable probability is one that is sufficient to undermine confidence in the outcome.” Zornes v. State , (quotations and citation omitted).
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State of Minnesota v. Bruce Archie Turner
Minn. Ct. App. 2025
To establish a Brady violation, a defendant must show (1) the evidence is favorable to him because it would have been either exculpatory or impeaching; (2) the evidence was suppressed by the prosecution, intentionally or otherwise; and (3) the evidence is material, “in other words, the absence of the evidence must have caused prejudice to the defendant.” (quotation omitted).
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State of Minnesota v. Oscar Elias Padilla Jovel
Minn. Ct. App. 2025
Respondent’s intentional or unintentional suppression of “material evidence favorable to the defendant violates the constitutional guarantee of due process.” Zornes v. State
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Sheila Maurise Burski v. State of Minnesota
Minn. Ct. App. 2024
“Evidence is material under Brady if there is a reasonable probability that, had the evidence been disclosed to the defense, the result of the proceeding would have been different.” (quotations omitted).
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State of Minnesota v. Michael Adam Davis
Minn. Ct. App. 2024
“Evidence is material under Brady if there is a reasonable probability that, had the evidence been disclosed to the defense, the result of the proceeding would have been different.” (quotations omitted).
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State of Minnesota v. John Kevin Melina
Minn. Ct. App. 2024
1 A defendant “must meet all three requirements to establish a Brady violation.”
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A21-0583 State of Minnesota v. Larry Joe Foster, A21-0070, Court of Appeals Nonprecedential, ...
Minn. Ct. App. 2024
“Evidence is material under Brady if there is a reasonable probability that, had the evidence been disclosed to the defense, the result of the proceeding would have been different.” (quotations omitted).
- State of Minnesota v. Royale Romeo Harris Minn. Ct. App. 2023
- State of Minnesota v. Michael Arthur Rock Minn. Ct. App. 2023
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State of Minnesota v. Michael James Lovestrand
Minn. Ct. App. 2023
if proven at an evidentiary hearing, must meet all three requirements to establish a Brady violation.”
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Kristopher Lee Roybal v. State of Minnesota
Minn. Ct. App. 2023
“Evidence is material under Brady if there is a reasonable probability that, had the evidence been disclosed to the defense, the result of the proceeding would have been different.” (quotation omitted).
- State of Minnesota v. Ainoi Manila Minn. Ct. App. 2023
- State of Minnesota v. John Ishmael Bradley, III Minn. Ct. App. 2023
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State of Minnesota,
Minn. 2023
(explaining that because “the trial transcript clearly shows that Zornes’s sister did testify at trial, the postconviction court’s finding is clearly erroneous”).
- State of Minnesota v. Bryant Jerome Stephenson Minn. Ct. App. 2023
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William Dumont White v. State of Minnesota
Minn. Ct. App. 2021
DECISION We review the denial of “a petition for postconviction relief for an abuse of discretion.” (quotation omitted).
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Joseph Christen Thoresen,
Minn. 2021
“Evidence is material if there is a reasonable probability that, had the evidence been disclosed to the 8 defense, the result of the proceeding would have been different.” Zornes v. State , (citation omitted) (internal quotatio n marks omitted).
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Antonio Deandre Johnson, Jr. v. State of Minnesota
Minn. Ct. App. 2021
at *3 (citing Zornes v. State , ).
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James Michael Soderbeck v. State of Minnesota
Minn. Ct. App. 2021
See also Zornes v. State , (applying this same standard).
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State of Minnesota v. Juanel Anthony Mikulak
Minn. Ct. App. 2020
A Brady violation occurs when (1) the evidence is favorable to the defendant; (2 ) the state withheld the evidence , “intentionally or otherwise ;” and (3) the evidence is material because its absence would “have caused prejudice to the defendant .”
- State of Minnesota v. Stanley Paul Wenell-Jack Minn. Ct. App. 2020
- Kenneth Eugene Andersen, Minn. 2020
- Leonard Goodloe, Minn. 2019
- State of Minnesota v. Richard Danell Dunston Minn. Ct. App. 2019
- Dean Aaron Anderson v. State of Minnesota Minn. Ct. App. 2019
- State of Minnesota v. Andrew Gary Jennissen Minn. Ct. App. 2019
- James Michael Soderbeck v. State of Minnesota Minn. Ct. App. 2019
- State of Minnesota v. Antonio Deandre Johnson, Jr. Minn. Ct. App. 2019
- State of Minnesota v. Adolfo Gutierrez Avila, Jr. Minn. Ct. App. 2019
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Julian Sanchez-Sanchez v. State of Minnesota
Minn. Ct. App. 2019
(“Because [defendant]’s attempt to invoke the Knaffla exceptions is merely an argumentative assertion without factual support, it fails as a matter of law.”).
- State of Minnesota v. Michael Peter Derevitsky Minn. Ct. App. 2019
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Crow v. State
923 N.W.2d 2
Minn. 2019
(quoting Brown v. State , , 617 (Minn. 2017) ); Zornes v. State , , 416 (Minn. 2017).
- Faron Wayne Ruel v. State of Minnesota Minn. Ct. App. 2019
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Jackson v. State
919 N.W.2d 470
Minn. 2018
See Zornes v. State , , 421 (Minn. 2017) (explaining that unraised claims that "should have been known" may be barred).
- Richard Willmar Rapatt v. State of Minnesota Minn. Ct. App. 2018
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Joseph Duane Gustafson, Jr. v. State of Minnesota
Minn. Ct. App. 2018
A claimed exception must be based on more than “an argumentative assertion without factual support”; otherwise, “it fails as a matter of law.”
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State of Minnesota v. Scott Alan Kepner
Minn. Ct. App. 2018
P. 9.01 provides that the state must disclose any written or recorded statements which relate to the case “within the possession or control of the prosecution” as well as any “[m]aterial or information in the prosecutor’s possession and control that tends to negate or reduce the defendant’s guilt.” 6 (quotation omitted).
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Andersen v. State
913 N.W.2d 417
Minn. 2018
Zornes v. State , , 416 (Minn. 2017).
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Armando DeLaCruz, Jr. v. State of Minnesota
Minn. Ct. App. 2018
“[T]he suppression by the State, whether intentional or not, of material evidence favorable to the defendant violates the constitutional guarantee of due process.” (alteration in original) (quotation omitted).
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Francisco Cleofus Mountain v. State of Minnesota
Minn. Ct. App. 2018
See Zornes v. State , -21 (Minn. 2017).
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Taylor v. State
910 N.W.2d 35
Minn. 2018
Zornes v. State , , 416 (Minn. 2017) (quoting Carridine v. State , , 492 (Minn. 2015) ).
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Howard v. State
909 N.W.2d 595
Minn. Ct. App. 2018
Zornes v. State , , 416 (Minn. 2017) (quotation omitted).