Cited by

Opinions in Minnesota that cite State v. Bakken, 604 N.W.2d 106.

96 citing documents.

State of Minnesota, Respondent, Minn. Ct. App. 2026
State of Minnesota, Respondent, Minn. Ct. App. 2026
“[A] prior consistent statement might bolster credibility by showing a fresh complaint, obviating an improper influence or motive, providing a meaningful context, or demonstrating accuracy of memory.” d 106, 109 (Minn. App. 2000).
State of Minnesota, Respondent, Minn. Ct. App. 2026
State of Minnesota, Respondent, Minn. Ct. App. 2026
Under rule 801(d)(1)(B), “a witness’s prior statement that is consistent with his trial testimony is admissible as nonhearsay evidence if the statement is helpful to the trier of fact in evaluating the witness’s credibility, and if the witness testifies at trial and is subject to cross-examination about the statement.” -09 (Minn. App. 2000), rev. denied (Minn. Feb.
State of Minnesota v. William Gray Peterson Minn. Ct. App. 2025
State of Minnesota v. William Gray Peterson Minn. Ct. App. 2025
d 106, 109 (Minn. App. 2000), rev. denied (Minn. Feb.
State of Minnesota, Respondent, Minn. Ct. App. 2025
State of Minnesota, Respondent, Minn. Ct. App. 2025
(prior consistent statement may bolster witness’s credibility by “obviating an improper influence or motive, providing a meaningful context, or demonstrating accuracy of memory”), rev. denied (Minn. Feb.
Jayce Evan Hernandez, petitioner, Appellant, Minn. Ct. App. 2025
” -110 (Minn. App. 2000) (emphasis added); see Minn. 801(d)(1)(B).
, A23-0930 Minn. Ct. App. 2025
See State v. Bakken , (noting that before a statement can be admitted as a prior consistent statement, a district court must determine “whether the prior statement and the trial testimony are consistent with each other”), rev. denied (Minn. Feb.
State of Minnesota, Respondent, Minn. Ct. App. 2025
7 Before a prior consistent statement can be admitted, the district court “must make a threshold determination of whether there has been a challenge to the witness’s credibility.” rev. denied (Minn. Feb.
A23-1240 Minn. Ct. App. 2024
- 09 (Minn. App. 2000), rev. denied (Minn. Feb.
State of Minnesota, Respondent, Minn. Ct. App. 2024
State of Minnesota, Respondent, Minn. Ct. App. 2024
- 09 (Minn. App. 2000), rev. denied (Minn. Feb.
State of Minnesota v. Raymont Michael Redmond Minn. Ct. App. 2024
State of Minnesota v. Raymont Michael Redmond Minn. Ct. App. 2024
7 For trial testimony and a prior statement to be consistent, they “need not be identical.” -25 (Minn. App. 2005); rev. denied (Minn. Feb.
State of Minnesota v. Walter Pierre Thomas Minn. Ct. App. 2024
State of Minnesota v. Walter Pierre Thomas Minn. Ct. App. 2024
(quotation omitted), rev. denied (Minn. Feb.
State of Minnesota, Respondent, Minn. Ct. App. 2024
State of Minnesota v. Curtis Dwayne Thurston Minn. Ct. App. 2023
State of Minnesota v. Curtis Dwayne Thurston Minn. Ct. App. 2023
“The trial testimony and the prior statement need not be verbatim.” rev. denied (Minn. Feb.
State of Minnesota v. Vin Khumpavong Minn. Ct. App. 2023
In the Matter of the Welfare of: G. V. G., Child. Minn. Ct. App. 2023
State of Minnesota, Respondent, Minn. Ct. App. 2023
801(d)(1)(B); -09 (Minn. 1997) (affirming admission of witness’s testimony about her prior out-of- court statement); -10 (Minn. App. 2000) (affirming admission of videotaped interview of victim on ground that victim’s testimony was central to case), rev. denied (Minn. Feb.
State of Minnesota, Respondent, Minn. Ct. App. 2023
State of Minnesota, Respondent, Minn. Ct. App. 2023
Otherwise, “a few consistent statements in a multi-statement interview may be used to bootstrap into evidence inconsistent statements that do not qualify under the rule.” State v. Bakken , rev. denied (Minn. Feb.
State of Minnesota, Respondent, Minn. Ct. App. 2023
State of Minnesota, Respondent, Minn. Ct. App. 2022
801(d)(1)(B), “a witness’s prior statement that is consistent with [her] trial testimony is admissible as non hearsay evidence if the statement is helpful to the trier of fact in evaluating the witness’s credibility, and if the witness testifies at trial and is subject to cross -examination about the statement.” d 106, 108-09 (Minn. App. 2000), rev. denied (Feb.
State of Minnesota, Respondent, Minn. Ct. App. 2022
State of Minnesota, Respondent, Minn. Ct. App. 2022
Otherwise, “a few consistent statements in a multi-statement interview may be used to bootstrap into evidence inconsistent statements that do not qualify under the rule .” rev. denied (Minn. Feb.
State of Minnesota, Respondent, vs. Marcel Dylan Zephier, Appellant. Minn. Ct. App. 2022
State of Minnesota, Respondent, vs. Jorge Alberto Martinez Reyes, Appellant. Minn. Ct. App. 2021
An out-of-court statement may be admitted as non-hearsay pursuant to rule 80l(d)(l)(B) if the district court makes a threshold determination that the witness's credibility has been challenged, review denied (Minn. Feb.
Paul Matthew Ashfeld, petitioner, Appellant, Minn. Ct. App. 2021
d 106, 109 (Minn. App. 2000), review denied (Minn. Feb.
State of Minnesota, Respondent, Minn. Ct. App. 2021
-48 (Minn. 2004); review denied (Minn. Feb.
State of Minnesota, Respondent, Minn. Ct. App. 2020
review denied (Minn. Feb.
State of Minnesota, Respondent, Minn. Ct. App. 2020
review denied (Minn. Feb.
State of Minnesota, Respondent, Minn. Ct. App. 2020
State v. Bakken , (quotation omitted), review denied (Minn. Jan.
State of Minnesota, Respondent, Minn. Ct. App. 2020
Rather, the district court must make a threshold determination that the witness’s credibility has been challenged , and “the statement must bolster the witness’ credibility w ith respect to that aspect of the witness’ credibility that was challenged.” Nunn, d at 909 ; review denied (Minn. Feb.
State of Minnesota, Respondent, Minn. Ct. App. 2020
review denied (Minn. Feb.
State of Minnesota, Respondent, Minn. Ct. App. 2020
The trial testimony and the prior statement need not be verbatim, State v. Bakken , review denied (Minn. Feb.
State of Minnesota, Respondent, Minn. Ct. App. 2019
review denied (Minn. Feb.
State of Minnesota, Respondent, Minn. Ct. App. 2019
801(d)(1)(B), “a witness’s prior statement that is consistent with his trial testimony is admissible as nonhearsay evidence if the statement is helpful to the trier of fact in evaluating the witness’s credibility, and if the witness testifies at trial and is subject to cross -examination about the statement.” State v. Bakken , -09 (Minn. App. 2000), review denied (Minn. Feb.
State of Minnesota, Respondent, Minn. Ct. App. 2019
d 106, 109 (Minn. App. 2000), review denied (Minn. Feb.
State of Minnesota, Respondent, Minn. Ct. App. 2019
Before a prior consistent statement can be admitted, the district court “must make a threshold determination of whether there has been a challenge to the witness’s credibility.” review denied (Minn. Feb.
State of Minnesota, Respondent, Minn. Ct. App. 2019
But “[t]he trial testimony and the prior statement need not be verbatim.” review denied (Minn. Feb.
State of Minnesota, Respondent, Minn. Ct. App. 2019
review denied (Minn. Feb.
State of Minnesota, Respondent, Minn. Ct. App. 2019
The Minnesota Rules of Evidence provide that “a witness’s prior statement that is consistent with his trial testimony is admissible as nonhearsay evidence if the statement is helpful to the trier of fact in evaluating the witness’s credibility, and if the witness 21 testifies at trial and is subject to cross-examination about the statement.” - 09 (Minn. App. 2000) (citing the Minnesota Rules of Evidence), review denied (Minn. Feb.
State of Minnesota, Respondent, Minn. Ct. App. 2019
State v. Bakken , review denied (Minn. Feb.
State of Minnesota, Respondent, Minn. Ct. App. 2019
“The trial testimony and the prior statement need not be verbatim.” review denied (Minn. Feb.
State of Minnesota, Respondent, Minn. Ct. App. 2019
State v. Bakken , rev iew denied (Minn. Feb.