Authorities cited
Identified automatically; this list may not be exhaustive.
- In re Olson ex rel. A.C.O. v. Olson 892 N.W.2d 837
- State v. Cram 718 N.W.2d 898
- State v. Shoen 598 N.W.2d 370
- State v. Sanders 775 N.W.2d 883
- State v. Lee 929 N.W.2d 432
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This opinion is nonprecedential except as provided by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
A25-0333
State of Minnesota,
Respondent
vs.
Bradley Martin Woida,
Appellant.
Filed December 22, 2025
Affirmed
Kirk, Judge*
Waseca County District Court
File No. 81-CR-24-215
Keith Ellison, Attorney General, St. Paul, Minnesota; and
Rachel V. Cornelius, Waseca County Attorney, Waseca, Minnesota (for respondent)
Cathryn Middlebrook, Chief Appellate Public Defender, Adam Lozeau, Assistant Public
Defender, St. Paul, Minnesota (for appellant)
Considered and decided by Reyes, Presiding Judge; Wheelock, Judge; and Kirk,
Judge.
* Retired judge of the Minnesota Court of Appeals, serving by appointment pursuant to
Minn. Const. art. VI, § 10.
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NONPRECEDENTIAL OPINION
KIRK, Judge
Appellant challenges his conviction of failing to register as a predatory offender,
arguing that the district court erred by admitting evidence that violated his rights under the
Confrontation Clause and contained inadmissible hearsay under the Minnesota Rules of
Evidence. We affirm.
FACTS
In late March 2024, appellant, Bradley Martin Woida, entered the Waseca County
Sheriff’s Office to update his predatory-offender registration. Woida told officers that he
had moved to Waseca on February 5, 2024, and that he had updated his registration on that
day. Woida explained that he returned because he had learned at a recent court appearance
that the February 5 registration “didn’t get filed in.” Officers reviewed security-camera
footage and documentary records from February 5 and found no evidence that Woida had
visited the sheriff’s office on that date. Finding that Woida had been living in Waseca for
over a month without having updated his registration, officers arrested Woida.
Respondent State of Minnesota charged Woida with one count of failure to fulfill
his predatory-offender registration requirement in violation of Minn. Stat. § 243.166, subd.
5(a)(1) (2022). Woida pleaded not guilty to the charge, waived his right to a jury trial, and
requested a court trial.
At the September 2024 court trial, the state called two officers and Woida’s
probation officer. The state also offered two exhibits: a body-worn-camera video from the
officers’ interaction with Woida and Woida’s predatory offender packet that the officers
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had received from the Bureau of Criminal Apprehension (BCA). Woida waived his right
to testify and called no additional witnesses.
Woida objected to admission of the predatory offender packet on hearsay,
authentication, and Confrontation Clause grounds. In particular, Woida took issue with a
partial copy of his original predatory offender registration form that listed his original
conviction. He argued that it was not self-authenticating and contained testimonial out-of-
court statements by a BCA official. The district court received the exhibit over Woida’s
objection.
Prior to closing arguments, Woida moved for acquittal, arguing that the state failed
to prove that he was a person required to register. The district court denied the motion,
finding that—even excluding the disputed evidence—there was sufficient evidence
establishing that Woida was required to register. Specifically, the district court relied on
the probation officer’s testimony that she had frequently spoken to Woida about his
registration requirements since May of 2023 , and the body-worn-camera video showing
Woida admitting to officers that he was required to register.
The district court found Woida guilty and sentenced him to 30 months’
imprisonment. Woida appeals.
DECISION
Woida argues that the district court erred because admission of the registration form
violated his rights under the Confrontation Clause and contained inadmissible hearsay
under the Minnesota Rules of Evidence. We affirm because, even if the district court erred,
any error was harmless.
4
This court applies an abuse-of-discretion standard of review to a district court’s
ruling on a hearsay objection. Olson ex rel. A.C.O. v. Olson, 892 N.W.2d 837, 841 (Minn.
App. 2017). “When an error does not implicate a constitutional right, we ask whether
‘there is a reasonable possibility that the wrongfully admitted evidence significantly
affected the verdict.’” State v. McNeilly, 6 N.W.3d 161, 189 (Minn. 2024) (quoting
State v. Cram, 718 N.W.2d 898, 904 n.1 (Minn. 2006)). When an error implicates a
constitutional right, appellate courts ask whether the error was harmless beyond a
reasonable doubt. Id. “For an error to be harmless beyond a reasonable doubt, the guilty
verdict . . . must be surely unattributable to the error.” State v. Shoen, 598 N.W.2d 370,
377 (Minn. 1999) (quotations omitted). When determining whether a verdict was surely
unattributable to an erroneous admission of evidence, appellate courts “consider the
manner in which the evidence was presented, whether it was highly persuasive, whether it
was used in closing argument, and whether it was effectively countered by the defendant.”
State v. Sanders, 775 N.W.2d 883, 888 (Minn. 2009) (quotation omitted). If the error
implicating a constitutional right was not harmless beyond a reasonable doubt, then
appellate courts “will award a new trial.” State v. Lee, 929 N.W.2d 432, 440 (Minn. 2019)
(quotation omitted).
We need not decide whether admission of the registration form violated Woida’s
rights under the Confrontation Clause or contained inadmissible hearsay because any error
was harmless beyond a reasonable doubt.
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Woida contends that any error cannot be harmless because the district court relied
on the registration form in its order. But in its order, the district court disclaimed reliance
on the registration form, stating that it “gives greater weight to the evidence contained in
[the body-worn-camera video] wherein the Defendant acknowledges his requirement to
register as a predatory offender on or about March 20, 2024.” Additionally, even at trial,
the district court declined to give any weight to the registration form when denying
Woida’s motion for acquittal. Instead, the court relied on the probation officer’s testimony
that she reminded Woida to register, and the body-worn-camera video showing Woida
admitting to officers that he was required to register. Therefore, any error in admitting the
form was harmless because the district court assigned the disputed evidence no persuasive
value.
Woida further contends that the error cannot be harmless because the conviction
could not be established absent the disputed evidence. But, as the district court stated, “it
is undisputed that the Defendant was required to register as a predatory offender as of
March 20, 2024, the date of the alleged violation of the registration requirements, based on
Defendant’s statements made to the officers in [the body-worn-camera video]
acknowledging his requirement to register as a predatory offender.” And this conclusion
is supported by the record. The body-worn-camera video shows an officer asking Woida,
“You know part of your requirements are to register within five days of where you move
to?” The body-worn-camera video shows Woida responding, “Yes.”
Therefore, because the district court’s guilty verdict was based entirely on evidence
independent of the challenged evidence, any constitutional error was harmless beyond a
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reasonable doubt. See Shoen, 598 N.W.2d at 377. Accordingly, any evidentiary error was
also harmless because—since the district court did not rely upon it—there is no “reasonable
possibility that the [disputed] evidence significantly affected the verdict.” See, McNeilly,
6 N.W.3d at 189 (quotation omitted).
Affirmed.