Cited by

Opinions in Minnesota that cite State v. Robinson, 427 N.W.2d 217.

121 citing documents.

State of Minnesota, Respondent, Minn. Ct. App. 2024
Bhujel relies on a supreme court case where the defendant’s prior assertion of similar defenses against similar allegations of criminal conduct demonstrated a “pattern of 9 operation” without “mistake or accident.”
State of Minnesota v. Blair Benedict Oberton Minn. 2024
State of Minnesota v. Blair Benedict Oberton Minn. 2024
In support of his argument, n.5 (Minn. 1988), in which we observed that “recordation of all pre-statement conversations would afford the reviewing court an objective record upon which to rule, rather than one based upon self-serving or subjective assertions of the principals involved.” In Scales, rather than deciding the due process iss
State of Minnesota v. Gary John Bogatz, Jr. Minn. Ct. App. 2023
State of Minnesota v. Gary John Bogatz, Jr. Minn. Ct. App. 2023
Where a suspect’s request for counsel is equivocal or ambiguous, but could be construed as a request for counsel, Minnesota law requires that all questioning cease except for “narrow questions designed to ‘clarify’ the accused’s true desires respecting counsel.”
State of Minnesota, Respondent, Minn. Ct. App. 2022
If a defendant agrees to proceed without counsel but later “makes an equivocal or ambiguous statement that could be construed as a request for counsel, investigators must cease questioning the suspect except as to ‘ narrow questions designed to “ clarify” the accused’s true desires respecting counsel.’” Ortega, d at 71 ( ).
State of Minnesota, Appellant, Minn. Ct. App. 2020
“[W]hen a suspect indicates by an equivocal or ambiguous statement, which is subject to a construction that the accused is requesting counsel, all further questioning must stop except that narrow questions designed to ‘clarify’ the accused’s true desires respecting counsel may continue.”
State v. Lee 929 N.W.2d 432 Minn. 2019
State v. Lee 929 N.W.2d 432 Minn. 2019
State v. Robinson , , 224 (Minn. 1988).
State of Minnesota, Respondent, Minn. Ct. App. 2018
-26 (Minn. 1988) (stating that an error was harmless when the amount of evidence of appellant’s guilt was overwhelming).
State of Minnesota, Respondent, Minn. Ct. App. 2017
When a Minnesota suspect make s an equivocal or ambiguous 4 statement that could be cons trued as a request for counse l, investigators must cease questioning the suspect except as to “narrow questions designed to ‘clarify’ the accused’s true desires respecting counsel.” State v. Robinson
State of Minnesota v. Antonio Lamonthe White Minn. Ct. App. 2016
State of Minnesota v. Antonio Lamonthe White Minn. Ct. App. 2016
Conversely, “[i]f the record contains overwhelming evidence of guilt, and the statement was merely cumulative and could not have played a significant role in the jury’s conviction, it is harmless.”
State of Minnesota v. Paul Joseph Welle 870 N.W.2d 360 Minn. 2015
State of Minnesota v. Paul Joseph Welle 870 N.W.2d 360 Minn. 2015
d 217, 227 (Minn. 1988).
State of Minnesota v. Nisius Dealvin McAllister 862 N.W.2d 49 Minn. 2015
State of Minnesota v. Nisius Dealvin McAllister 862 N.W.2d 49 Minn. 2015
Although the presentation of a self-incriminating statement during trial is a powerful piece of evidence for the State, “a determination that the trial court erred in admitting the statement does not per se result in reversal of the conviction for a new trial.” see also United States v. Santos, 235 F.3d 1105, 1108 (8th Cir. 2000) (affirming a conviction because any error in admitting two confessions was harmless beyond a reasonable doubt).
State v. Castillo-Alvarez 836 N.W.2d 527 Minn. 2013
State v. Castillo-Alvarez 836 N.W.2d 527 Minn. 2013
We have previously recognized that the Scales requirement has a procedural purpose — preserving an accurate record of an interrogation, and a substantive purpose — "discouraging] unfair and psychologically coercive police tactics” resulting "in [a] more professional law enforcement.” Scales, d at 591 ; , 224 n. 5 (Minn.1988) (asking law enforcement to record interrogation before the adoption of Scales , not only to create an "objective record,” but also to validate the "integrity of the actual i
State v. Ortega 813 N.W.2d 86 Minn. 2012
State v. Ortega 813 N.W.2d 86 Minn. 2012
But our case law imposes an additional obligation on officers when a suspect makes an equivocal request for counsel: officers must cease questioning the suspect except as to “narrow questions designed to ‘clarify’ the [suspect’s] true desires respecting counsel.”
State v. Ortega 798 N.W.2d 59 Minn. 2011
State v. Ortega 798 N.W.2d 59 Minn. 2011
We will review de novo the application of the “stop and clarify” but defer to any factual findings by the district court that are not clearly erroneous.
State v. Chavarria-Cruz 784 N.W.2d 355 Minn. 2010
State v. Chavarria-Cruz 784 N.W.2d 355 Minn. 2010
Where a suspect’s request is “equivocal or ambiguous” but “subject to a construction that the accused is requesting counsel, all further questioning must stop except that narrow questions designed to ‘clarify’ the accused’s true desires respecting counsel may continue.” quoted in Risk, d at 647-48 .
State v. Sanders 775 N.W.2d 883 Minn. 2009
State v. Sanders 775 N.W.2d 883 Minn. 2009
State v. Chavarria-Cruz 771 N.W.2d 883 Minn. Ct. App. 2009
State v. Chavarria-Cruz 771 N.W.2d 883 Minn. Ct. App. 2009
But the Minnesota Supreme Court has held “that when a suspect indicates by an equivocal or ambiguous statement, which is subject to a construction that the accused is requesting counsel, all further questioning must stop except that narrow questions designed to ‘clarify the accused’s true desires respecting counsel may continue.”
State v. Scanlon 719 N.W.2d 674 Minn. 2006
State v. Scanlon 719 N.W.2d 674 Minn. 2006
State v. Moon 717 N.W.2d 429 Minn. Ct. App. 2006
State v. Moon 717 N.W.2d 429 Minn. Ct. App. 2006
(citing Miranda v. Arizona, 384 U.S. 436, 475 , 86 S.Ct.
State v. Edwards 717 N.W.2d 405 Minn. 2006
State v. Inman 692 N.W.2d 76 Minn. 2005
State v. Inman 692 N.W.2d 76 Minn. 2005
at 591 ( , 224 n. 5 (Minn.1988)).
State v. Al-Naseer 678 N.W.2d 679 Minn. Ct. App. 2004
State v. Al-Naseer 678 N.W.2d 679 Minn. Ct. App. 2004
State v. Ray 659 N.W.2d 736 Minn. 2003
State v. Ray 659 N.W.2d 736 Minn. 2003
State v. Conger 652 N.W.2d 704 Minn. 2002
State v. Conger 652 N.W.2d 704 Minn. 2002
-33 (Minn.1991); , 224 n. 5 (Minn.1988).
State v. Hannon 636 N.W.2d 796 Minn. 2001
State v. Hannon 636 N.W.2d 796 Minn. 2001
The trial court concluded that, “[appellant’s] poorly enunciated statement, ‘[c]an I have a drink of water and then lock me up I think we really should have an attorney,’ is, if anything, an equivocal request for an attorney.” the court recognized that, since there was an equivocal request for counsel, the investigating officers were required to stop asking any more questions except those narrowly tailored to clarify appellant’s true desire with respect to counsel.
State v. Bradford 618 N.W.2d 782 Minn. 2000
State v. Bradford 618 N.W.2d 782 Minn. 2000
State v. Risk 598 N.W.2d 642 Minn. 1999
State v. Risk 598 N.W.2d 642 Minn. 1999
we hold that in order to protect an accused’s right to counsel under the state constitution, police must stop questioning and must clarify an accused’s intentions if the accused makes a statement during custodial interrogation that could reasonably be construed as an expression of a desire to deal with th
State v. Munson 594 N.W.2d 128 Minn. 1999
State v. Munson 594 N.W.2d 128 Minn. 1999
In discussing the first step in the Edwards analysis