Cited by
Opinions in Minnesota that cite State v. Conklin, 444 N.W.2d 268.
-
State of Minnesota, Respondent,
Minn. Ct. App. 2026
ied honestly or dishonestly at th e trial here in the courtroom, not to determine whether the statements she made are accurate accounts of what the State alleges happened.” D-6 as substantive evidence, while leaving her direct testimony intact, was no substitute for the “[f]ace-to-face confrontation [that] is ‘the core of the values furthered by the Confrontation Clause.’” (quoting Coy v. Iowa, 487 U.S. 1012, 1017 (1988)); see also Coy, 487 U.S. at 1017 (“[T]here is something deep in human natur
- In the Matter of the Welfare of: E. J. C. L., Child Minn. Ct. App. 2025
-
In the Matter of the Welfare of: E. J. C. L., Child
Minn. Ct. App. 2025
4(c) establishes a permissible exception to the confrontation clause because it requires a specific finding that the denial of the right to confrontation is necessary to effectuate an important public policy.”
-
State of Minnesota, Appellant,
Minn. Ct. App. 2025
Under this standard, “the state has the burden to show that the errors are harmless beyond a reasonable doubt by showing that the error did not contribute to the verdict obtained.”
- State of Minnesota, Respondent, Minn. Ct. App. 2025
- State of Minnesota v. Cody Logan Fohrenkam Minn. Ct. App. 2024
-
State of Minnesota v. Cody Logan Fohrenkam
Minn. Ct. App. 2024
The burden is on the state to show that the constitutional error is harmless beyond a reasonable doubt, meeting this burden “by showing that the error did not contribute to the verdict.”
-
State of Minnesota, Respondent,
Minn. Ct. App. 2024
In State v. Conklin, the Minnesota Supreme Cou rt stated that section 595.02, subdivision 4(c), “establishes a permissible exception to the confrontation clause.”
-
State of Minnesota, Respondent,
Minn. Ct. App. 2022
(“When constitutional errors are involved, the state has the burden to show that the errors are harmless beyond a reasonable doubt by showing that the error did not contribute to the verdict obtained.”).
-
In the Matter of the Welfare of the Children of: A. O. K. and C. L. K., Parents.
Minn. Ct. App. 2021
It admitted the out-of- court statements of victim 2 and victim 3 and determining that the statements wer e reliable.
-
State of Minnesota,
Minn. 2021
The burden is on the State “to show that the errors are harmless beyond a reasonable doubt by showing that the error did not contribute to the verdict obtained.”
- Gregory Levon Spraggins, Jr. v. State of Minnesota Minn. Ct. App. 2015
-
Gregory Levon Spraggins, Jr. v. State of Minnesota
Minn. Ct. App. 2015
(stating that prohibition against admission of hearsay statements “protect[s] the integrity of the factfinding process by ensuring that only reliable evidence will be used against a defendant.
- State of Minnesota v. Wilfred Carl Hudson Minn. Ct. App. 2015
-
State of Minnesota v. Wilfred Carl Hudson
Minn. Ct. App. 2015
4 and having found “by specific evidence that the particular witness is or would be psychologically traumatized and that traumatization is substantially caused by the presence of the defendant.” 274 (Minn. 1989).
- State of Minnesota v. Stephen Richard Angotti Minn. Ct. App. 2014
-
State of Minnesota v. Stephen Richard Angotti
Minn. Ct. App. 2014
whether the person talking with the child had a preconceived idea of what the child would say[,] and the lack of leading or suggestive questions.” L.E.P., d at 170 ().
- State v. Kuhlmann 806 N.W.2d 844 Minn. 2011
-
State v. Kuhlmann
806 N.W.2d 844
Minn. 2011
1246 , 113 L.Ed.2d 302 (1991) (“[T]he Court has applied harmless-error analysis to a wide range of errors and has recognized that most constitutional errors can be harmless.”); (“When constitutional errors are involved, the state has the burden to show that the errors are harmless beyond a reasonable doubt by showing *851 that the error did not contribute to the verdict obtained.”).
- State v. Ahmed 782 N.W.2d 253 Minn. Ct. App. 2010
-
State v. Ahmed
782 N.W.2d 253
Minn. Ct. App. 2010
for the proposition that the credibility of the witness who testifies to the out-of-court statement is another circumstance that must be considered before reliability is determined.
- State v. Hannon 703 N.W.2d 498 Minn. 2005
- State v. Hannon 703 N.W.2d 498 Minn. 2005
- State v. Sime 669 N.W.2d 922 Minn. Ct. App. 2003
- State v. Sime 669 N.W.2d 922 Minn. Ct. App. 2003
- In Re the Welfare of M.P.Y. 630 N.W.2d 411 Minn. 2001
- In Re the Welfare of M.P.Y. 630 N.W.2d 411 Minn. 2001
- State v. Cole 594 N.W.2d 197 Minn. Ct. App. 1999
- In Re the Welfare of L.E.P. 594 N.W.2d 163 Minn. 1999
-
In Re the Welfare of L.E.P.
594 N.W.2d 163
Minn. 1999
Minnesota courts have articulated a number of additional factors to consider in evaluating the reliability of out-of-court statements by young children including “the knowledge of the declarant, the motives of the declarant and witnesses to speak truthfully and the proximity in time between the statement and the events described.” cert.
- State v. Peterson 530 N.W.2d 843 Minn. Ct. App. 1995
- State v. Peterson 530 N.W.2d 843 Minn. Ct. App. 1995
- State v. Lee 494 N.W.2d 475 Minn. 1993
- State v. Edwards 485 N.W.2d 911 Minn. 1992
-
State v. Edwards
485 N.W.2d 911
Minn. 1992
(case preceding Wright).
- State v. Lee 480 N.W.2d 668 Minn. Ct. App. 1992
-
State v. Lee
480 N.W.2d 668
Minn. Ct. App. 1992
(citing Chapman v. California, 386 U.S. 18, 23-24 , 87 S.Ct.
- State v. Larson 472 N.W.2d 120 Minn. 1991
-
State v. Larson
472 N.W.2d 120
Minn. 1991
(case preceding Wright).
- State v. Lanam 459 N.W.2d 656 Minn. 1990
-
State v. Lanam
459 N.W.2d 656
Minn. 1990
Relevant cases of this court interpreting and applying the statute include:
- State v. Ross 451 N.W.2d 231 Minn. Ct. App. 1990
- State v. Ross 451 N.W.2d 231 Minn. Ct. App. 1990
- State v. Larson 447 N.W.2d 593 Minn. Ct. App. 1989
-
State v. Larson
447 N.W.2d 593
Minn. Ct. App. 1989
2531, 2537 , 65 L.Ed.2d 597 (1980) (citations omitted)