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Evidence offered under section 634.20 is known as “relationship 3 A “victim’s reaction to the threat is circumstantial evidence relevant to the element of intent.” rev. denied (Minn. July 16, 1998).

is not, by itself, a basis to claim coercion.” rev. denied (Minn. July 16, 1998).

ctive’s full name and birth date, Andersen stating that he would kill the detective upon his release, Andersen’s “angry” and “rage[ful]” demeanor, Andersen’s aggressive behavior in swinging his belly belt at the cell door, and the detective’s fearful response 5 to Andersen’s 5 A “victim’s reaction to the threat is circumstantial evidence relevant to the element of intent.” rev. denied (Minn. July 11 threat all support the rational hypothesis that Andersen intended to terrorize the detective or,

However, “the normal trauma associated with being incarcerated following an arrest is not, by itself, a basis to claim coercion.” Sykes v. State

rev. denied (Minn. July 16, 1998).

A “victim’s reaction to the threat is circumstantial evidence relevant to the element of 8 intent.” Sykes v. State , review denied (Minn. July 16, 1998).

This court has stated that “the normal trauma associated with being incarcerated following an a rrest is not, by itself, a basis to ” withdraw a guilty plea, review denied (Minn. July 16, 1998) , and that a defendant ’s “ability to negotiate a presentence release .

to feel terrorized , and a “victim’s reaction to the threat is circumstantial evidence relevant to the element of intent.” , 811 (Minn. App. 1998), review denied (Minn. July 16, 1998).

Th ough that terror is not an element of threats of violence, it is “circumstantial evidence relevant to the element of intent.” Sykes v. State , review denied (Minn. July 16, 1998); see also State v. Jones , (affirming sufficiency of circumstantial evid ence based, in part, on the f act that the victim felt threatened), review denied (Minn. Feb.

“[T]he normal trauma associated with being incarcerated following an arrest is not, by itself, a basis to claim coercion.” review denied (Minn. July 16, 1998).

-13 (Minn. App. 1998), review denied (Minn. July 16, 1998) (being “emotionally distraught” and wanting to be home for Christmas are part of “normal trauma” associated with incarceration) .

review denied (Minn. July 16, 1998).

(stating that for 6 plea to be involuntary, it must have been achieved through “mental coercion overbearing the will of the defendant” or “actual or threatened physical harm” (quotations omitted)), review denied (Minn. July 16, 1998).

However, this court has held that “the normal trauma associated with being incarcerated following an arrest is not, by itself, a basis to claim coercion.” review denied (Minn. July 16, 1998).

(“The effect of a terroristic threat is not an essential element of the offense, but the victim’s reaction to the threat is circumstantial evidence relevant to the element of intent.”), review denied (Minn. July 16, 1998).

is not, by itself, a basis to claim coercion.” review denied (Minn. July 16, 1998); see Raleigh, d at 96 (holding that defendant’s acknowledgment that he “was under extreme stress and not thinking rationally when he entered his plea” did not make his plea involuntary).

Minn. Stat. § 609.025(1) (2010); review denied (Minn. July 16, 1998).

d 807, 809, 813–14 (Minn. App. 1998) (rejecting defendant’s “claim[] that the factual basis for guilt [of felony terroristic threats] is lacking because he was never questioned about his intent or state of mind at the time he sent the letter or made the telephone call” on the basis that “[t]he district court could readil

is not, by itself, a basis to claim coercion.” review denied (Minn. July 16, 1998).

A Minnesota district court has jurisdiction over a criminal case if the defendant has “commit[ted] an offense in whole or in part within this state.” Minn. Stat. § 609.025(1) (2012); review denied (Minn. July 16, 1998).

To find a plea to be involuntary due to coercion, the record must unequivocally support a finding that the coercion resulted in “overbearing the will of the defendant.” review denied (Minn. July 16, 1998).

See, (holding under “manifest injustice” standard that a defendant’s claim that he “was under extreme stress and not thinking rationally when he entered his plea” did not provide a ground for plea withdrawal); (stating that “the normal trauma associated with being incarcerated following an arrest is not, by itself, a basis to claim coercion”), review denied (Minn. July 16, 1998).

In support of that argument, Hernandez- Espinoza’s brief cites only one case, review denied (Minn. Jul.

review denied (Minn. July 16, 1998).

812 (Minn.App.1998), rev. denied (Minn. July 16, 1998) (noting that a Minnesota “victim’s reaction to the threat is circumstantial evidence relevant to the element of intent” and holding that jurisdiction existed under Minn.Stat.

“For a guilty plea to be valid, it must be accurate, voluntary, and intelligent (i.e., knowingly and understandingly made).” (quotation omitted), review denied (Minn. July 16, 1998).

See, (holding that threat to prosecute fully a defendant if he does not plead guilty is constitutional); (finding nothing improper about statement by state that it will fully prosecute if there is no plea agreement because state is merely pointing out its legal authority to prosecute defendants who plead not guilty and go to trial), review denied (Minn. July 16, 1998), cert.