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A. The State’s Reason for the Discovery Violation The first Lindsey factor looks at the justification for the prosecuting attorney ’s failure to disclose and whether the discovery violation was “motivated by bad faith,” Lindsey, d at 373, or was “the result of inadvertence ,”

(ordering a new trial because prosecutors persisted in employing tactics condemned by this court); (ordering a new trial to underscore the importance of compliance with discovery obligations); (ordering a new trial to ensure prosecutors comply with evidentiary rules, even when the evidence of guilt was overwhelming).

Manila argues the district court abused its discretion by excluding testimony about the comparative test results of two baggies collected at Manila’s residence because it was 4 Manila cites State v. Kaiser for the proposition that the supreme court “has adopted lesser requirements of prejudice than the federal courts for violations of discovery rules.”

“When det ermining whether alleged failure to investigate constitutes ineffective “even where prejudice cannot be shown.” State v. Kaiser , (noting that we have reversed without a showing of prejudice “on occasion”)

-87 (Minn. 1992); See Minn. R. Crim.

ne of Jenkins’s arguments was that the “police failed to collect GPS data from the taxicab that allegedly transported [him] after the murders, failed to collect a wallet at the crime scene, failed to 5 We recognize that “[a] prosecutor cannot circumvent the requirement of open-file discovery by not taking notes or by not putting things in the file that belong in the file.”

We have previously granted new trials “in the interests of justice when necessary to protect the integrity of judicial proceedings.” (-86 (Minn. 1992)).

a new trial for the state’s failure to notify the defense of evidence that bore on his decision to waive marital privilege); (granting a new trial in the interests of justice for the state’s failure to disclose information concerning culpability of a third party, which might have led the defense to other useful information); -87 (Minn. 1992) (granting a new 8 trial for failure to disclose the victim’s statement that cast doubt on identification of the defendant, coupled with the prosecutor’s ass

and H.W., (applying our supervisory authority “to enforce the Rules of Juvenile Protection Procedure”); -86 (Minn.1992) (exercising our supervisory authority to protect evidentiary rules from erosion).

Moreover, we used our supervisory power to effect change in prosecutors' behavior during discovery by ordering a new trial based on a prosecutor’s nonprejudicial failure to comply with the discovery rules.

-86 (Minn.1992) (holding that in exercise of our supervisory powers over trial courts and in the interests of justice, we may, in order to protect evidentiary rules from erosion, award a new trial for the prosecution’s breach of discovery rules even though required showing of prejudice has not been made).

-87 (Minn.1992) (stating that a showing of prejudice is usually required to obtain a new trial after the State violates a discovery rule and that a new trial without a showing of prejudice is the exception).

( (“[Ajlthough the evidence of defendant’s guilt was strong, we conclude that a new trial is required in the interests of justice and to insure that the reciprocal discovery rules adopted by this court are observed by both the prosecution and t

1 See Salitros, d at 820 (reversing the conviction prophylae-tically in the exercise of the court’s supervisory power and in the interests of justice); (same); (concluding that a new trial was not warranted but emphasizing that “[p]rosecutors are officers of the court * * * and we will not hesitate in a suitable case to grant relief in the form of a new trial”).

763 , 31 L.Ed.2d 104 (1972)

("Our cases require much more of the prosecution than the federal cases require and do not always insist on a traditional showing of prejudice in order to justify a new trial.”); State v, Schwantes, d

11; Randall, 238 Minn. at 14 , d at 771 .

(new trial granted prophylac-tically even though “it is at least arguable that the defense was not prejudiced by nondisclosure and that therefore a new trial is not required”); (guilty verdict reversed prophylactically, quoting Kaiser).