Cited by
Opinions in Minnesota that cite State v. Graham, 371 N.W.2d 204.
- State of Minnesota v. Daniel Martez Walker Minn. Ct. App. 2026
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State of Minnesota v. Daniel Martez Walker
Minn. Ct. App. 2026
argument on appeal rests on his contention that R.C.’s mother’s testimony “went beyond typical ‘spark of life’ testimony.” “Spark of life” evidence consists of biographical testimony about the victim to show that “[t]he victim was not just bones and sinews covered with flesh, but was imbued with the spark of life.” -26 (Minn. 2016) (d 204, 207 (Minn. 1985)).
- A24-1797 Minn. Ct. App. 2025
- State of Minnesota v. Timothy Lee Heller Minn. 2024
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State of Minnesota v. Timothy Lee Heller
Minn. 2024
12 “Spark of life” evidence consists of biographical testimony about the victim to show that “[t]he victim was not just bones and sinews covered with flesh, but was imbued with the spark of life.” –26 (Minn. 2016) ().
- State of Minnesota, Respondent, Minn. Ct. App. 2024
- State of Minnesota v. Demetrius Antonio Wynne Minn. Ct. App. 2024
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State of Minnesota v. Demetrius Antonio Wynne
Minn. Ct. App. 2024
Reasoning that a “victim was not just bones and sinews covered with flesh, but was imbued with the spark of life[,]” the Minnesota Supreme Court has held that “[t]he prosecution has some leeway to show that spark and present the victim as a human being.” –27 (Minn. 2013) (alteration in original) ().
- State of Minnesota, Respondent, Minn. Ct. App. 2022
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State of Minnesota, Respondent,
Minn. Ct. App. 2020
See, e.g., State v. Graham , (“If the defendant does not go forward with such evidence, there is no right to the self-defense instruction.” (emphasis added)).
- State of Minnesota, Respondent, Minn. Ct. App. 2020
- State of Minnesota, Respondent, Minn. Ct. App. 2019
- State of Minnesota, Respondent, Minn. Ct. App. 2018
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State of Minnesota, Respondent,
Minn. Ct. App. 2018
replied, “Yes, I think that I could do that.” We defer to the district court’s ruling on challenges for cause because the district court is “in the best position to observe and judge the demeano r of the prospective juror.” State v. Graham
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State of Minnesota, Respondent,
Minn. Ct. App. 2018
-09 (Minn. 1990); d 204, 206 (Minn. 1985).
- State of Minnesota, Respondent, Minn. Ct. App. 2018
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Anthony Strickland, petitioner, Appellant,
Minn. Ct. App. 2018
State v. Graham , -09 (Minn. 1985).
- State of Minnesota, Respondent, Minn. Ct. App. 2018
- State of Minnesota, Respondent, Minn. Ct. App. 2018
- State of Minnesota, Respondent, Minn. Ct. App. 2018
- State of Minnesota, Respondent, Minn. Ct. App. 2017
- State of Minnesota, Respondent, Minn. Ct. App. 2017
- State of Minnesota v. Mary Marie Garner Minn. Ct. App. 2016
- State of Minnesota v. Mary Marie Garner Minn. Ct. App. 2016
- State of Minnesota v. Tyrese Thomas Minn. Ct. App. 2016
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State of Minnesota v. Tyrese Thomas
Minn. Ct. App. 2016
“A reviewing court should give deference to the district court’s ruling on challenges for cause because the district court is ‘in the best position to observe and judge the demeanor of the prospective juror.’” (); (holding that the question of whether a juror is impartial is a credibility determination and that appellate courts defer to a district court’s finding of impartiality).
- STATE of Minnesota, Respondent, Appellant, v. Byron David SMITH, Appellant, Respondent 876 N.W.2d 310 Minn. 2016
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STATE of Minnesota, Respondent, Appellant, v. Byron David SMITH, Appellant, Respondent
876 N.W.2d 310
Minn. 2016
We have allowed such evidence at trial “so long as it is not an attempt to invoke undue sympathy or inflame the passions of the jdry,” ().
- State of Minnesota v. Angel Maldonado, Jr. Minn. Ct. App. 2015
- State of Minnesota v. Angel Maldonado, Jr. Minn. Ct. App. 2015
- State of Minnesota v. Bradley James Richards Minn. Ct. App. 2015
- State of Minnesota v. Bradley James Richards Minn. Ct. App. 2015
- State of Minnesota v. Stacy Dean Darrell Minn. Ct. App. 2015
- State of Minnesota v. Stacy Dean Darrell Minn. Ct. App. 2015
- State of Minnesota v. Ronald Matthew Quiceno Minn. Ct. App. 2015
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State of Minnesota v. Ronald Matthew Quiceno
Minn. Ct. App. 2015
See, –07 (Minn. 1985) (upholding district court’s decision not to remove juror for cause when prospective juror stated that in the past she had believed defendant to be guilty but currently believed she could presume defendant innocent and fairly try case).
- State of Minnesota v. Jesse Keith Fultz Minn. Ct. App. 2014
- State of Minnesota v. Jesse Keith Fultz Minn. Ct. App. 2014
- State v. Fairbanks 842 N.W.2d 297 Minn. 2014
- State v. Fairbanks 842 N.W.2d 297 Minn. 2014
- State v. Morrow 834 N.W.2d 715 Minn. 2013
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State v. Morrow
834 N.W.2d 715
Minn. 2013
Although “it is true that the quality or personal details of the victim’s life are not strictly relevant to the issue of who murdered the victim, it would seem to tie unduly the hands of the prosecutor to prohibit any mention of the victim’s life.”
- State v. Swinger 800 N.W.2d 833 Minn. Ct. App. 2011
- State v. Swinger 800 N.W.2d 833 Minn. Ct. App. 2011
- State v. Prtine 784 N.W.2d 303 Minn. 2010
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State v. Prtine
784 N.W.2d 303
Minn. 2010
A reviewing court should give deference to the district court’s ruling on challenges for cause because the district court is “in the best position to observe and judge the demean- or of the prospective juror.” see also Logan, d at 323 (holding that the question of whether a juror is impartial is a credibility determination and that appellate courts defer to a district court’s finding of impartiality).
- State v. Evans 756 N.W.2d 854 Minn. 2008
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State v. Evans
756 N.W.2d 854
Minn. 2008
In other words, we have said that the prosecution may present evidence that the victim was more than “just bones and sinews covered with flesh”; rather, the victim was “imbued with the spark of life.”
- State v. Johnson 719 N.W.2d 619 Minn. 2006
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State v. Johnson
719 N.W.2d 619
Minn. 2006
) (stating that “[t]he process of *630 going forward with evidence is complete when the defendant submits reasonable evidence”); -73 (Minn.1986) (determining that there was no evidence that defendant, who was the original aggressor, had clearly-manifested the good-faith intention to withdraw required when seeking a self-defense instruction); (determining that one element of self-defense argument was “not supported with any evidence”) (emphasis added).