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Relationship evidence is distinct from rule 404(b) bad-acts evidence because it evinces “prior conduct between the accused and the alleged victim and may be offered to illuminate the history of the relationship, that is, to put the crime charged in the context of the relationship between the two.” superseded by statute 2002 Minn. Laws ch. 314, § 9, at 516 (codified at Minn. Stat. § 634.20 (2002)), as recognized in Lindsey, d at 755.

Relationship evidence is treated differently than other “collateral” Spreigl evidence partly because “[d]omestic 7 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.”

The purpose of relationship evidence is to “illuminate the history of the relationship” and “put the crime charged in the context of the relationship between the two.”

The Minnesota Supreme Court has stated that evidence of prior domestic abuse “is evidence of prior conduct between the accused and the alleged victim and it may be offered to illuminate the history of the relationship, that is, to put the crime charged in the context of the relationship between the two.”

See Minn. Stat. § 634.20 (providing that relationship evidence “is admissible unless the probative value is substantially outweighed by the danger of unfair prejudice” or other listed factors); (concluding that evidence submitted under section 634.20 need not meet the clear-and- convincing standard of proof).

“[T]he purpose of the notice requirement is to prevent a defendant from being taken by surprise by the introduction of evidence of collateral bad acts.”

5 In State v. McCoy, the supreme court adopted “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.”

how the defendant treats those closest to him, how [he] treats his family or household members.” Caselaw identifies that Minn. Stat. § 634.20 is designed to aid in the prosecution of domestic abuse, which is often particularly challenging because it “typically occurs in the privacy of the home,” “frequently involves a pattern of activity,” and “is often underreported.”

Evidence of prior domestic abuse by the accused against the alleged victim “may be offered to illuminate the history of the relationship, that is, to put the crime charged in the context of the relationship between the two.”

404(b).” d 153, 158 (Minn. 2004).

It is true that “we have the inherent judicial authority to regulate and supervise the rules that govern the admission of evidence in the lower courts.” ().

Minn. Stat. § 634.20 (2012)

Evidence of prior domestic conduct between a defendant and a victim may be offered to “illuminate the history of the relationship, that is, to put the crime charged in the context of the relationship between the two.”

“[T]he purpose of the notice requirement is to prevent a defendant from being taken by surprise by the introduction of evidence of collateral bad acts.”

But relationship evidence is distinct from rule 404(b) bad-acts evidence because it evinces “prior conduct between the accused and the alleged victim and may be offered to illuminate the history of the relationship, that is, to put the crime charged in the context of the relationship between the two.”

15 Relationship evidence is treated differently than other “collateral” evidence, partly because “[d]omestic 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.”

(the constitution delegates rules of evidence exclusively to the courts) (quoting In re Tracy, 197 Minn. 35, 46, 266 N.W.

(), review denied (Minn. Oct.

Minn. Stat. § 634.20 (2014)