The holding in the court’s own words
Because we conclude the district court’s decision to exclude the evidence was not an abuse of discretion and did not deprive Bailey of his constitutional right to present a complete defense, we affirm. For these reasons, we conclude the district court appropriately exercised its discretion under rule 403 when it excluded the evidence that ex-girlfriend suffered from anxiety and PTSD from a prior relationship.
Quoted verbatim from the opinion — no paraphrase, nothing generated. Not yet human-reviewed. How we find the holding.
Authorities cited
Identified automatically; this list may not be exhaustive.
- State of Minnesota v. Neal Curtis Zumberge 888 N.W.2d 688
- State v. Guzman 892 N.W.2d 801
- State v. Crims 540 N.W.2d 860
- State of Minnesota v. Eddie Matthew Mosley 853 N.W.2d 789
- State v. Hallmark 927 N.W.2d 281
- State v. Hunt 615 N.W.2d 294
- State v. Hawkins 260 N.W.2d 150
- Olstad v. Fahse 282 N.W. 694
- State v. Pass 832 N.W.2d 836
Opinion text
This opinion is nonprecedential except as provided by
Minn. R. Civ. App. P. 136.01, subd. 1(c).
STATE OF MINNESOTA
IN COURT OF APPEALS
A24-1317
State of Minnesota,
Respondent,
vs.
James Earl Bailey,
Appellant.
Filed November 17, 2025
Affirmed
Larson, Judge
Hennepin County District Court
File No. 27-CR-24-2279
Keith Ellison, Attorney General, St. Paul, Minnesota; and
Mary F. Moriarty, Hennepin County Attorney, Robert I. Yount, Assistant County Attorney,
Minneapolis, Minnesota (for respondent)
Cathryn Middlebrook, Chief Appellate Public Defender, Jessica Merz Godes, Assistant
Public Defender, St. Paul, Minnesota (for appellant)
Considered and decided by Connolly, Presiding Judge; Larson, Judge; and Bond,
Judge.
NONPRECEDENTIAL OPINION
LARSON, Judge
On direct appeal, appellant James Earl Bailey challenges his false -imprisonment
conviction. Bailey argues he is entitled to a new trial due to the district court’s decision to
exclude evidence that the alleged victim suffered from anxiety and post-traumatic-stress
2
disorder (PTSD). Because we conclude the district court’s decision to exclude the evidence
was not an abuse of discretion and did not deprive Bailey of his constitutional right to
present a complete defense, we affirm.
FACTS
In January 2024, respondent State of Minnesota charged Bailey with one count of
false imprisonment under Minn. Stat. § 609.255, subd. 2 (2024), and one count of domestic
assault under Minn. Stat. § 609.2242, subd. 4 (2024). The complaint alleged that Bailey
intentionally confined or restrained L.M. (ex-girlfriend) in a vehicle without her consent
while she drove to various locations. The following facts were elicited at a jury trial.
Bailey and ex-girlfriend were in an intimate relationship lasting approximately three
months that ended in December 2023. Toward the end of the relationship, Bailey exhibited
concerning behaviors toward ex- girlfriend, including acting jealous and using gendered
slurs. He also sent text messages threatening to “stab [her] in [the] neck,” send her to the
“sky, clouds,” or “heaven,” and “kill” anyone in his way. Ex-girlfriend felt “hurt” and
“scared,” and Bailey’s behavior “made [ex-girlfriend’s] anxiety go up.”
A month after Bailey and ex-girlfriend ended their relationship, Bailey “popped all
four” tires on ex-girlfriend’s car. He also continued sending threatening text messages and
told ex-girlfriend that she could not “dat[e] or see[] anyone but [him].” Thereafter, on
January 27, 2024, ex-girlfriend told Bailey to remove his possessions from her storage unit.
The two interacted at the storage unit several times that day in ways that made ex-girlfriend
feel nervous. Then, in the evening, Bailey calmly approached ex-girlfriend while she was
3
in her car and asked if she would drive him to a fast-food restaurant. Ex-girlfriend agreed,
and Bailey sat down in the car.
Ex-girlfriend started driving toward the fast -food restaurant, and the situation
escalated quickly. Bailey started accusing ex-girlfriend of “trying to go see another guy.”
Bailey “snatched” ex-girlfriend’s phone from her hand and read through her text messages.
Then, Bailey turned off ex-girlfriend’s phone and refused to return it. Next, Bailey insisted
that ex-girlfriend drive them to a secluded spot near a lake, despite ex-girlfriend’s request
to talk in a more crowded place. Ex-girlfriend became “very nervous.”
When they neared the lake, ex-girlfriend planned to jump out of the car near a police
officer. When ex-girlfriend removed her seatbelt, the noise alerted Bailey. Bailey grew
“angrier” and grabbed ex-girlfriend’s arm and wrist, pulling her towards him. After ex-
girlfriend re-buckled her seatbelt, Bailey said, “Try something stupid. I see that cop car up
there.” While still holding her wrist as they drove past the police officer, Bailey grabbed
his backpack and dared ex-girlfriend to “[t]ry something.” Ex-girlfriend did not know the
backpack’s contents but feared that it contained a gun or knife. Ex-girlfriend felt that
Bailey prevented her from leaving the car. She had an “anxiety attack,” “started crying,”
and felt “really scared.”
As they continued looking for a place to park near the lake, Bailey kept complaining
that the parking areas had “too many people” and were “not dark enough.” At that moment,
ex-girlfriend felt that Bailey “was going to do something, hurt [her] or something else.”
After further discussion, the pair drove to a pharmacy. Upon arriving, Bailey told
ex-girlfriend, “not to try anything stupid, not to try anything at all.” Bailey told ex-
4
girlfriend he planned to hold her hand inside the store. While they walked around inside,
ex-girlfriend felt that she could not leave because Bailey still had her phone and stayed
“real[ly] close” to her.
After leaving the pharmacy, they drove to another lake. Bailey calmed down and
returned ex- girlfriend’s phone. Ex-girlfriend sent a photo to her cousin to verify her
whereabouts. Then the pair drove to a retail store. On their way, Bailey became “paranoid”
that ex-girlfriend had called someone and that they were being followed.
When they arrived at the retail store, ex-girlfriend went to the bathroom to call her
cousin. After leaving the bathroom, ex -girlfriend saw Bailey walking nervously and
“looking in the aisles.” Ex-girlfriend called Bailey’s name. Then ex-girlfriend saw her
brother, worried that brother and Bailey would fight, and started running toward the exit.
Bailey began to run as well, yelling that someone had accused him of kidnapping ex-
girlfriend. Ex-girlfriend stopped at the entrance; Bailey continued to run.
Moments later, ex-girlfriend’s cousin arrived with law enforcement, who took ex -
girlfriend to a security office inside the retail store. Law enforcement located Bailey at a
nearby hotel, took him into custody, and brought him back to the retail store’s parking lot.
When ex-girlfriend learned that Bailey was on the premises, ex-girlfriend started shaking
and hyperventilating. Ex-girlfriend then said , “He’s going to kill me. I told you guys.
He’s going to get me because I got him locked up.” Ex-girlfriend also told law enforcement
that she “has anxiety and PTSD from a prior relationship.”
Prior to trial, the state filed a motion to prohibit Bailey from eliciting testimony
regarding ex-girlfriend’s alleged anxiety or PTSD from a prior relationship. The district
5
court granted the state’s motion, determining the evidence was “not relevant.” See Minn.
R. Evid. 401, 402. The district court explained that it did not “see how anxiety or PTSD
affects a witness’ ability to relay or recall events” and did not “think anxiety or PTSD
ma[d]e it more or less likely that a witness might be truthful.” The district court also
excluded the evidence under Minn. R. Evid. 403, on the basis that “if there is any
relevance . . . it is substantially outweighed by the potential for unfair prejudice.”
After trial, t he jury found Bailey guilty of false imprisonment and not guilty of
domestic assault. The district court entered a conviction for the false-imprisonment count
and sentenced Bailey to 36 months in prison.
Bailey appeals.
DECISION
Bailey challenges the district court’s evidentiary decision to exclude evidence that
ex-girlfriend suffered from anxiety and PTSD from a prior relationship. According to
Bailey, he is entitled to a new trial because the district court improperly excluded the
evidence and deprived him of his constitutional right to present a complete defense.
“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 v.
Zumberge, 888 N.W.2d 688, 694 (Minn. 2017). “A district court abuses its discretion when
its decision is based on an erroneous view of the law or is against logic and the facts in the
record.” State v. Guzman, 892 N.W.2d 801 , 810 (Minn. 2017). Although a defendant
enjoys a right to present evidence that is “material and favorable to their theory of the case,”
6
they have “no right to introduce evidence that either is irrelevant, or whose prejudicial
effect outweighs its probative value.” State v. Crims, 540 N.W.2d 860, 866 (Minn. App.
1995) (emphasis omitted), rev. denied (Minn. Jan. 23, 1996).
We first review the district court’s decision to exclude the evidence under rule 403.1
Under rule 403, a district court can exclude relevant evidence “if its probative value is
substantially outweighed by the danger of unfair prejudice, confusion of the issues, or
misleading the jury, or by considerations of undue delay, waste of time, or needless
presentation of cumulative evidence.” As used in the rule, the word “prejudice” means an
“unfair advantage that results from the capacity of the evidence to persuade by illegitimate
means,” and not “damage to the opponent’s case that results from the legitimate probative
force of the evidence.” State v. Mosley, 853 N.W.2d 789, 797 (Minn. 2014) (quotation
omitted). Consequently, if relevant evidence could persuade “the jury through illegitimate
means, it must be excluded from trial.” State v. Hallmark, 927 N.W.2d 281, 299 (Minn.
2019).
Here, the district court found that the evidence was only marginally relevant at best,
and that any relevance was “substantially outweighed by the potential for unfair prejudice.”
We conclude the district court did not abuse its discretion. The record amply supports that
the evidence may have caused unfair prejudice. Because ex -girlfriend’s statement
regarding anxiety and PTSD included allusions to an unrelated, prior abusive relationship,
1 Bailey also challenges the district court’s decision to exclude the evidence under rule 402.
But we need not reach that issue because the evidence was properly excluded under
rule 403.
7
the district court reasonably determined that introducing the evidence could have mislead
the jury.
Bailey disagrees, relying on State v. Hunt, 615 N.W.2d 294 (Minn. 2000), to argue
the district court improperly balanced the evidence because anxiety and PTSD could affect
ex-girlfriend’s “ability to accurately perceive and recall the events.” 2 We are not
persuaded.
In Hunt, the supreme court concluded that the state violated a defendant’s
constitutional right to due process when it failed to disclose medical evidence that a witness
had been found incompetent to stand trial. 615 N.W.2d at 300-01. Hunt is distinguishable
for two reasons. First, Hunt evaluates the disclosure of evidence, not its admissibility under
the Minnesota Rules of Evidence. Id. at 299-301. Second, unlike Hunt, no medical
evidence was ever produced that ex-girlfriend, in fact, suffers from anxiety and PTSD. Id.
at 297-98, 301. And Bailey did not offer any evidence to explain how anxiety or PTSD
could impact ex-girlfriend’s ability to perceive and remember events.
For these reasons, we conclude the district court appropriately exercised its
discretion under rule 403 when it excluded the evidence that ex-girlfriend suffered from
anxiety and PTSD from a prior relationship.
2 Bailey also relies on intoxication cases to support his argument that “a witness’s mental
condition that may affect their ability to accurately perceive and relate to events is relevant
and admissible.” It is well established that intoxication during an incident can impair a
person’s ability to perceive and remember events. See, e.g., State v. Hawkins, 260 N.W.2d
150, 158 (Minn. 1977) (citing Olstad v. Fahse, 282 N.W. 694, 696 (Minn. 1938)). But
Bailey does not provide any authority that the same is true for anxiety or PTSD.
8
Moreover, we conclude the district court did not deprive Bailey of the right to
present a complete defense when it excluded this evidence. “The right of a defendant to
present a complete defense . . . is guaranteed by the Due Process Clause of both the United
States Constitution and the Minnesota Constitution.” State v. Foster, 20 N.W.3d 6, 18
(Minn. 2025) (quotation and citations omitted). But application of rule 403 is
“unquestionably constitutional.” State v. Pass, 832 N.W.2d 836, 842 (Minn. 2013)
(quotation omitted). Because the district court appropriately exercised its discretion under
rule 403 when it excluded evidence that ex-girlfriend suffered from anxiety and PTSD from
a prior relationship, we conclude the district court did not deprive Bailey of his right to
present a complete defense.
Affirmed.