The holding in the court’s own words
Because we conclude the state acted within its discretion when it admitted the challenged evidence, we affirm. Upon review of the record, we conclude that Amigon preserved the issue for appeal when he filed a motion in limine arguing the challenged evidence did not qualify as relationship evidence. Thus, we conclude that the amendment did not overrule prior precedent.
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 v. Bell 719 N.W.2d 635
- State v. McCoy 682 N.W.2d 153
- 941 N.W.2d 730 not in our corpus
- 966 N.W.2d 803 not in our corpus
- 986 N.W.2d 696 not in our corpus
- 960 N.W.2d 230 not in our corpus
- State v. Matthews 779 N.W.2d 543
- State v. McCurry 770 N.W.2d 553
- State v. Lindsey 755 N.W.2d 752
- State v. Schulz 691 N.W.2d 474
- State v. Hormann 805 N.W.2d 883
- State v. Kennedy 585 N.W.2d 385
- In Re Petition for DISCIPLINARY ACTION AGAINST Barbara Ann NIMIS, a Minnesota Attorney, Registration No. 235428 858 N.W.2d 535
- State v. Courtney 696 N.W.2d 73
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This opinion is nonprecedential except as provided by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
A25-0832
State of Minnesota,
Respondent,
vs.
Miguel Saavedra Amigon,
Appellant.
Filed April 20, 2026
Affirmed
Larson, Judge
Stearns County District Court
File No. 73-CR-24-7078
Keith Ellison, Attorney General, Christina Brown, Assistant Attorney General, St. Paul,
Minnesota; and
Janelle Kendall, Stearns County Attorney, St. Cloud, Minnesota (for respondent)
Cathryn Middlebrook, Chief Appellate Public Defender, Andrea Barts, Assistant Public
Defender, St. Paul, Minnesota (for appellant)
Considered and decided by Larson, Presiding Judge; Johnson, Judge; and Schmidt,
Judge.
NONPRECEDENTIAL OPINION
LARSON, Judge
In this direct appeal, appellant Miguel Saavedra Amigon argues he is entitled to a
new trial because the district court abused its discretion when it allowed the state to present
2
certain relationship evidence under Minn. Stat. § 634.20 (2024). Because we conclude the
state acted within its discretion when it admitted the challenged evidence, we affirm.
FACTS
In September 2024, police officers responded to a report of an assault involving
Amigon and his then fiancée (victim) at their home. That evening, Amigon and victim had
a verbal disagreement, which escalated into a physical altercation. During the incident,
Amigon yelled obscenities at victim and damaged victim’s personal belongings. Amigon
then physically assaulted victim—grabbing victim, tearing open victim’s blouse, and
breaking the necklace victim was wearing. Victim’s children witnessed the incident. The
children attempted to pull Amigon off victim, and victim’s daughter (daughter) called 911.
Amigon eventually left the house.
Officers arrived shortly thereafter and took statements from victim and daughter.
Officers later located and arrested Amigon. R espondent State of Minnesota charged
Amigon with felony domestic assault-fear under Minn. Stat. § 609.2242, subd. 4 (2024).1
Before trial, the state filed notice of its intent to introduce “relationship evidence”
under section 634.20.2 The state’s notice sought to admit eleven instances of alleged
relationship evidence. Amigon’s defense counsel objected in a motion in limine on the
grounds that the evidence outlined in the notice did not qualify as relationship evidence
1 Amigon stipulated to the fact that he had previous domestic-violence convictions which
enhanced the current domestic-assault charge to a felony.
2 The term “relationship evidence” is generally used to describe evidence admitted under
section 634.20. See, e.g., State v. Bell, 719 N.W.2d 635, 638 n.4 (Minn. 2006).
3
and was unduly prejudicial. The district court determined that seven instances were
admissible, but the district court limited the number of instances the state could introduce.3
At trial, the state called several witnesses, including victim. As relevant here, prior
to victim’s testimony, the district court gave a cautionary instruction regarding the
relationship evidence, stating that the evidence was “offered for the limited purpose of
demonstrating the nature and extent of the relationship between . . . Amigon and [victim]
in order for [the jury] to assist in determining whether [Amigon] committed the acts with
which he is charged in the complaint.” The district court further stated: “Amigon [was]
not being tried for and may not be convicted of any behavior other than the charged offense.
[The jury was] not to convict . . . Amigon on the basis of the alleged conduct in [the prior
incidents].” Victim then testified about three prior incidents involving Amigon.
First, victim testified about an incident that occurred in July 2016 (2016 incident).
Amigon pushed victim onto a bed during an argument. Amigon held victim down and
yelled obscenities at her. Victim’s sister was present during the incident and called the
police. Victim minimized the incident to the police due to Amigon’s intimidation and
coercion.
Second, victim testified about an incident that occurred in January 2019
(2019 incident). One evening, victim and Amigon argued about victim’s plans to go out
with friends. When victim left the house, Amigon called victim repeatedly and went to
3 The district court indicated the state could introduce “four instances” of relationship
evidence—including as an “instance” all victim’s prior recantations. Thus, the state
complied with this limitation when it admitted evidence of the three incidents described
below, plus victim’s prior recantation of two of those incidents.
4
victim’s location. T he next morning, Amigon physically and verbally assaulted victim.
Bleeding, victim ran to the neighbor’s house and told them to call the police. Victim
suffered a swollen eye for nearly two weeks, which daughter corroborated. Victim reported
the incident to the police but later recanted because victim feared Amigon and felt guilty.
Third, victim testified about an incident that occurred in Las Vegas (Las Vegas
incident). Amigon and victim argued while on vacation with friends. Eventually, the two
were shoving each other , and victim demanded that Amigon leave. Amigon left and
returned to their shared hotel room. Victim went to a friend’s hotel room for a few hours.
When victim returned to the shared hotel room, Amigon had destroyed several of victim’s
personal belongings. Victim did not report the incident to the police.
Amigon invoked his right not to testify.
4 The district court repeated its cautionary
instruction regarding the relationship evidence during final jury instructions. The jury
found Amigon guilty. The jury also returned a special-verdict form, finding that the
offense was committed in the presence of a child. The district court sentenced Amigon to
a 60-month prison term.
Amigon appeals.
DECISION
Amigon challenges the district court’s decision to allow the state to admit
relationship evidence under section 634.20. We review a district court’s evidentiary
rulings for an abuse of discretion. State v. McCoy, 682 N.W.2d 153, 161 (Minn. 2004).
4 Amigon asserted that he acted in self-defense, and the jury was given a self-defense
instruction.
5
“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. Vangrevenhof, 941 N.W.2d
730, 736 (Minn. 2020). Section 634.20 provides:
Evidence of domestic conduct by the accused against
the victim of domestic conduct, or against other family or
household members, is admissible unless the probative value
is substantially outweighed by the danger of unfair prejudice,
confusion of the issue, or misleading the jury, or by
considerations of undue delay, waste of time, or needless
presentation of cumulative evidence. ‘Domestic conduct’
includes, but is not limited to, evidence of domestic abuse . . .
[listing other offenses].
Amigon asserts the district court abused its discretion in two respects. First, Amigon
argues certain aspects of victim’s testimony do not meet the definition of “domestic
conduct” under the section 634.20. Second, Amigon asserts the district court improperly
weighed the prejudicial effect of the evidence. We address each argument in turn.
A.
Amigon argues the district court abused its discretion when it allowed victim to
testify about certain aspects of the three incidents. Specifically, he asserts that certain
aspects of victim’s testimony did not constitute “domestic conduct” under section 634.20.5
To resolve this question, we must first interpret section 634.20.
5 The state argues Amigon forfeited this argument on appeal. We are not persuaded.
Parties are allowed to refine their arguments on appeal. See State v. Woolridge Carter,
9 N.W.3d 839, 842 n.3 (Minn. 2024) (explaining that “the forfeiture doctrine does not
apply” when a party “has simply refined [their] arguments” on appeal). Upon review of
the record, we conclude that Amigon preserved the issue for appeal when he filed a motion
in limine arguing the challenged evidence did not qualify as relationship evidence.
6
Statutory interpretation is a question of law that we review de novo. State v. Holl ,
966 N.W.2d 803, 808 (Minn. 2021). Our goal when interpreting a statute “is to effectuate
the intent of the Legislature.” State v. Velisek, 986 N.W.2d 696, 699 (Minn.
2023) (quotation omitted). We must first determine if the statute is ambiguous. State v.
Mikell, 960 N.W.2d 230, 238 (Minn. 2021). A statute is ambiguous if its language “is
subject to more than one reasonable interpretation[.]” Holl, 966 N.W.2d at 808 (quotation
omitted). If the statute is unambiguous, we must apply the plain language. Id.
According to Amigon, a 2013 amendment to section 634.20 narrowed what
constitutes admissible relationship evidence. The 2013 amendment modified the statute as
follows:
Evidence of similar domestic conduct by the accused
against the victim of domestic abuse conduct, or against other
family or household members, is admissible unless the
probative value is substantially outweighed by the danger of
unfair prejudice, confusion of the issue, or misleading the jury,
or by considerations of undue delay, waste of time, or needless
presentation of cumulative evidence. “Similar Domestic
conduct” includes, but is not limited to, evidence of domestic
abuse . . . [listing other offenses].
See 2013 Minn. Laws ch. 47, § 7, at 208. In essence, the legislature replaced the word
“similar” with “domestic.”
Amigon contends that these modifications overruled previous precedent interpreting
the statute. Specifically, Amigon argues that “domestic conduct” must be interpreted to
mean conduct that amounts to “domestic abuse” and the phrase “not limited to” must be
construed in relation to the specific offenses listed in section 634.20. Thus, Amigon
asserts, prior appellate cases holding that “‘ [s]imilar conduct’ under [section] 634.20 is
7
broader than the enumerated offenses that constitute domestic abuse” are no longer good
law. See State v. Matthews, 779 N.W.2d 543, 549 (Minn. 2010) (emphasis added); see also
McCoy, 682 N.W.2d at 161 (holding section 634.20 allows state to admit relationship
evidence that “illuminates the history of the relationship between an accused and a victim”
and provides context to the charged crime); State v. McCurry, 770 N.W.2d 553, 560 (Minn.
App. 2009) (concluding phrase “not limited to” in section 634.20 encompasses “general
testimony about the relationship”), rev. denied (Minn. Oct. 28, 2009). The state disagrees,
arguing the change from “similar” to “domestic” did not alter prior interpretations of the
scope of admissible relationship evidence under section 634.20.
We agree with the state. Reviewing the statute’s plain language, while the
legislature replaced the word “similar” with the word “domestic,” the legislature did not
alter the definition of similar/domestic conduct. 6 Instead, the term is still defined as
“includ[ing], but is not limited to, evidence of domestic abuse[.]” See Minn. Stat. § 634.20
(2024). Thus, we conclude that the 2013 amendment did not overrule prior precedent. As
such, “domestic conduct” under section 634.20 is “broader than the enumerated offenses
that constitute domestic abuse,” see Matthews, 779 N.W.2d at 549, and the statute permits
the state to offer more “general testimony about the relationship,” see McCurry, 770
N.W.2d at 560.
6 Post-2013, the only substantive change to the definition was the addition of another
offense, violation of a domestic abuse no contact order, to the list of non-exclusive offenses
that qualify as “domestic conduct.” Minn. Stat. § 634.20 (2024); cf. Minn. Stat. § 634.20
(Supp. 2013).
8
This interpretation is further bolstered by our more recent precedential opinions
employing that broader definition. For example , in State v. Boswell, the appellant argued
that certain testimony was inadmissible because “not all of it was ‘domestic conduct’ under
section 634.20.” 20 N.W.3d 640, 652 (Minn. App. 2025). We rejected the appellant’s
argument that this testimony was not relationship evidence, stating the phrase “not limited
to” encompasses “general testimony about the relationship, including conduct that does not
rise to the level of the crimes listed in the definition of ” domestic conduct. Id. (quoting
McCurry, 770 N.W.2d at 560).
For these reasons, we conclude the 2013 amendment did not overrule prior
precedent regarding what constitutes relationship evidence under section 634.20.
With the standard clarified, we address Amigon’s challenges to victim’s testimony.
Amigon argues the following testimony was inadmissible under section 634.20: (1) victim
explaining her recantations and minimizations to the police following the 2016 incident
and 2019 incident (recanting evidence); (2) victim describing her injuries from the
2019 incident (injury evidence); and (3) victim describing her damaged personal property
from the Las Vegas incident (property-damage evidence). We are not persuaded. Under
existing precedent, the recanting evidence was admissible because it shed light on the “fear
and control dynamic” in Amigon’s and victim’s relationship. See Boswell, 20 N.W.3d at
653. The injury evidence is plainly allowable under the definition of “domestic abuse.”
See Minn. Stat. § 634.20; see also Minn. Stat. § 518B.01, subd. 2 (2024) (defining domestic
abuse as “physical harm, bodily injury, or assault” and “the infliction of fear of imminent
physical harm, bodily injury, or assault” against a family or household member). And the
9
property-damage evidence was admissible to illustrate an “ongoing tension [or]
argument[]” between Amigon and victim. See McCurry, 770 N.W.2d at 560.
Accordingly, we conclude the district court did not abuse its discretion when it
determined the challenged testimony was relationship evidence under section 634.20.
B.
Amigon argues that, even if the challenged aspects of victim’s testimony qualified
as relationship evidence under section 634.20, the district court abused its discretion in the
manner that it weighed the probative value of the evidence against the danger of unfair
prejudice. Under section 634.20, relationship evidence is admissible “unless the probative
value is substantially outweighed by the danger of unfair prejudice, confusion of the issue,
or misleading the jury, or by considerations of undue delay, waste of time, or needless
presentation of cumulative evidence.” Amigon raises three challenges to the district court’s
application of this balancing test, which we address in turn.
Amigon first argues the relationship evidence had little probative value because the
state had a strong case. We are not persuaded. “[W]hile the need for section 634.20
evidence is naturally considered as part of the assessment of” the balancing test, “a separate
analysis of need is not required to admit evidence under section 634.20.” Boswell,
20 N.W.3d at 653. Here, the state used the relationship evidence to bolster victim’s
credibility. But, importantly, Amigon also used the relationship evidence to attack victim’s
credibility. Thus, the proffered relationship evidence had significant probative value
because it “illuminate[d] the history of the relationship . . . and . . . assist[ed] the jury in
assessing witness credibility.” See Matthews, 779 N.W.2d at 549 (quotation omitted); see
10
also State v. Lindsey , 755 N.W.2d 752, 757 (Minn. App. 2008) (determining the
relationship evidence “had significant probative value in assisting the jury to judge witness
credibility”), rev. denied (Minn. Oct. 29, 2008).
Amigon argues second that the district court did not properly apply the balancing
test because the relationship evidence presented a “particularly great” risk that the jury
would misuse the evidence for improper character or propensity purposes.
7 “Unfair
prejudice . . . is not merely damaging evidence, even severely damaging evidence; rather,
unfair prejudice is evidence that persuades by illegitimate means, giving one party an unfair
advantage.” State v. Schulz, 691 N.W.2d 474, 478 (Minn. 2005). We are not persuaded
that the district court abused its discretion when it determined that the relationship evidence
would not persuade by illegitimate means. The proffered testimony was admissible under
section 634.20 because it illuminated the “relationship between an accused and a victim.”
See McCoy, 682 N.W.2d at 161. And the record shows that the district court carefully, and
explicitly, considered the prejudicial effect of the relationship evidence and limited the
number of instances the state could introduce to mitigate any prejudicial effect.
7 To support his argument, Amigon cites State v. Hormann. 805 N.W.2d 883 (Minn. App.
2011), rev. denied (Minn. Jan. 17, 2012). In Hormann, the victim testified to “four discrete
incidents,” which we concluded were “admissible as relationship evidence.” Id. at 890.
However, the victim also offered “more general statements about the marriage” that lacked
specificity. Id. at 891. We determined the general statements lacked probative value,
which was outweighed by the risk of unfair prejudice. We are not persuaded that Hormann
supports a different outcome in this case because victim’s testimony was akin to that
offered regarding the “four discrete incidents” and did not amount to general statements
about the parties’ relationship.
11
Third, Amigon argues the district court’s cautionary instructions did not effectively
mitigate the danger of unfair prejudice. We disagree. “[C]autionary instructions ‘lessen[]
the probability of undue weight being given by the jury to the evidence.’” Lindsey, 755
N.W.2d at 757 (quoting State v. Kennedy, 585 N.W.2d 385, 392 (Minn. 1998)); see also
State v. Benton, 858 N.W.2d 535, 542 (Minn. 2015) (stating that the potential for unfair
prejudice from relationship evidence may be lessened by the district court providing a
cautionary instruction to the jury). Here, the district court gave a cautionary instruction
both before victim’s testimony and during its final instructions. In the cautionary
instructions, the district court clearly articulated that the evidence was “offered for [a]
limited purpose” and reminded the jury that they could not “convict [Amigon] on the basis
of the alleged conduct in” the three incidents. We presume the jury followed that
instruction. See State v. Courtney, 696 N.W.2d 73, 84 (Minn. 2005) . Thus, we conclude
the cautionary instruction mitigated the relationship evidence’s prejudicial effect.
Accordingly, we conclude the district court did not abuse its discretion in its
application of the balancing test.
Affirmed.