Cited by

See, (recognizing that an attorney’s statements and arguments at trial are not evidence).

Minn. Stat. § 634.20 (2022); (adopting Minn. Stat. § 634.20 as a rule of evidence).

unless the probative value is substantially outweighed by the danger of unfair prejudice.”1 Minn. Stat. § 634.20; (adopting Minn. Stat. § 634.20 as a rule of evidence).

A court must give a plain reading to any statute it construes, and when the language of the statute is clear, the court must not engage in any further construction.” (quotation and citation omitted).

and Campbell’s competing narratives, the “inflammatory nature” of the letters “tipped the scale by leading the jury to conclude that Campbell is generally a bad person who deserves punishment and probably committed the charged offense.” Relationship evidence “illuminate[s] the history of the relationship” and “put[s] the crime charged in the context of the relationship.”

602), d 153, 160 n.6 (Minn. 2004).2 Dahir argues that Bauer compels admission of the recording of his police interview.

Although the arguments of counsel are not evidence , “[t]here is a difference between considering arguments by counsel as evidence and considering concessions by counsel that certain evidence does or does not exist,” n.2 (Minn. App. 2009), rev. denied (Minn. Mar.

850 (determining that the district court did not abuse its discretion by admitting statements of a declarant who appeared “scared,” “shaky,” and “very upset”); (holding that the excited utterance exception applied when the declarant was “very upset,” 11 “extremely agitated,” and “very afraid”)

Relationship evidence is also admissible to “provide[] context for the crime charged,” which may “assist[] the jury” in “judg[ing] the credibility of the principals in the relationship.”

unless the probative value is substantially outweighed by the danger of unfair prejudice.” Minn. Stat. § 634.20 (2022); (adopting Minn. Stat. § 634.20 as a rule of evidence).

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.” Minn. Stat. § 634.20; (adopting Minn. Stat. § 634.20 as a rule of evidence).

“The object of all interpretation and construction of laws is to ascertain and effectuate the intention of the legislature.” Minn. Stat. § 645.16 (2022); (applying Minn. Stat. § 645.16 (2002)).

(stating that a district court’s decision to admit relationship evidence in a domestic-abuse prosecution is reviewed for an abuse of discretion).

Such relationship evidence is generally admissible “unless the probative value is substantially outweighed by the danger of unfair prejudice, confusion of the issue, or misleading the jury.” Minn. Stat. § 634.20; d 153, 156 n.1 (Minn. 2004); (adopting the statute as a rule of evidence).

Under Minn. Stat. § 634.20, the state may be allowed to present “[e]vidence of domestic conduct by the accused against the victim of domestic conduct.” Such evidence, often called “relationship evidence,” is intended to “illuminate the history of the relationship” and “put the crime charged in the context of the relationship between the 7 two.”

Relationship evidence “illuminates the history of the relationship,” and “put[s] the crime charged in the context of the relationship between the two.” State v. McCoy

“The object of all interpretation and construction of laws is to ascertain and effectuate the intention of the legislature.” Minn. Stat. § 645.16 (2020); (applying Minn. Stat. § 645.16 (2002)).

“The statute is unambiguous—evidence of similar conduct 6 in domestic abuse trials is relevant and admissible unless it should be excluded for the reasons listed.”

Generally, “evidence of similar conduct in domestic abuse trials is relevant and admissible unless it should be excluded for the reasons listed.”

There is “inherent value of evidence of past acts of violence committed by the same defendant against the same victim,” because it “illuminate[s] the history of the relationship, that is, [it] put[s] the crime charged in the context of the relationship between the two .”

(“[T]he questions and arguments of attorneys are not evidence.” (quotation omitted)).

“Domestic abuse is unique in that it typically occurs in the privacy of the home, it frequently involves a pattern of activity that may escalate over time, and it is often underreported.”

A court “must give a plain reading to any statute it construes, and when the language of the statute is clear, the court must not engage in any further construction.” (citation omitted).

“Domestic abuse is unique in that it typica lly occurs in the privacy of the home, it frequently involves a pattern of activity that may escalate over time, and is often underreported.” State v. McCoy , (discussing the rationale for Minn. Stat. § 634.20’s relatively lax standard to admit prior-relationship evidence).

See generally State v. McCoy , (discussing argument of legal counsel).

The state presented relationship evidence of Larkins’s past intimidating conduct toward both the victim and the victim’s son, which served to “illuminate the history of the relationship” and “put the 16 crime charged in the context of the relationship between the two.” State v. McCoy

The supreme court has “expressly adopt[ed] Minn. Stat. § 634.20 as a rule of evidence for the admission of evidence of similar conduct by the accused against the alleged victim of domestic abuse.” d 153, 161 (Minn. 2004).4 Relationship evidence, however, is not admissible if its “probative value is substantially outweighed by the danger of unfair prejudice.” Minn. Stat. § 634.20.

overruled on other grounds by State v. McCoy , n.6 (Minn. 2004).

The supreme court has indicated that evidence admitted under Minn. Stat. § 634.20 can assist the jury “by providing a context with which it could better judge the credibility of the principals in the relationship.”

see also State v. Fraga , -27 (Minn. 2015) (recognizing that McCoy adopted section 634.20 as rule of evidence that includes evidence of domestic conduct by the accused against family or household members other than the victim).

See State v. McCoy , (adopting Minn. Stat. § 634.20 as a rule of evidence separate from the requirements of rule 404(b)).

Minn. Stat. § 634.20 (2014); see also State v. Fraga , -27 (Minn. 2015)

State v. McCoy , d 153, 161 (Minn. 2004).