Cited by
Opinions in Minnesota that cite State v. Bakken, 604 N.W.2d 106.
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State of Minnesota, Respondent,
Minn. Ct. App. 2019
review denied (Minn. Feb.
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State of Minnesota, Respondent,
Minn. Ct. App. 2019
review denied (Minn. Feb.
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State of Minnesota, Respondent,
Minn. Ct. App. 2018
review denied (Minn. Feb.
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State of Minnesota, Respondent,
Minn. Ct. App. 2018
See State v. Bakken , review denied (Minn. Feb.
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State of Minnesota, Respondent,
Minn. Ct. App. 2018
Trial testimony and the challenged stat ement “need not be verbatim.” review denied (Minn. Feb.
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State of Minnesota, Respondent,
Minn. Ct. App. 2018
–10 (Minn. App. 2000 ) (stating that “trial testimony and the [declarant’s] prior statement need not be verbatim,” and that an inconsistent statement falls outside the bounds of rule 801(d)(1)(B) wh en the inconsistency “directly affects the elements of the criminal charge”), review denied (Minn. Feb.
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State of Minnesota, Respondent,
Minn. Ct. App. 2018
“One of the traditional methods of challenging a witness’s credibility is the use of prior inconsistent statements.” State v. B akken, .
- State of Minnesota, Respondent, Minn. Ct. App. 2017
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State of Minnesota, Respondent,
Minn. Ct. App. 2017
“The trial testimony and the prior statement need not be identical to be consistent, and admission of a [prior] statement that is reasonably consistent with the trial testimony is not reversible error.” (citation and quotation omitted); (“The trial testimony and the prior statement need not be verbatim.”), review denied (Minn. Feb.
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State of Minnesota, Respondent,
Minn. Ct. App. 2017
review denied (Minn. Feb.
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State of Minnesota, Respondent,
Minn. Ct. App. 2017
801(d)(1)(B), a witness’s prior statement that is consistent with her trial testimony is admissible as nonhearsay evidence if the statement is helpful to the jury in evaluating the witness’s credibility, “and if the witness testi fies at trial and is subject to cross-examination about the statement.” - 09 (Minn. App. 2000), review denied (Minn. Feb.
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State of Minnesota, Respondent,
Minn. Ct. App. 2017
11 ( review denied (Minn. Feb.
- State of Minnesota v. Joshua David Donson Minn. Ct. App. 2017
- State of Minnesota v. Filbert Okari Onyoni Minn. Ct. App. 2017
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State of Minnesota v. Joshua David Donson
Minn. Ct. App. 2017
review denied (Minn. Feb.
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State of Minnesota v. Filbert Okari Onyoni
Minn. Ct. App. 2017
This “may be especially true when a crime victim is recounting a traumatic or stressful event.” review denied (Minn. Feb.
- State of Minnesota v. John Joseph Plevell 889 N.W.2d 584 Minn. Ct. App. 2017
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State of Minnesota v. John Joseph Plevell
889 N.W.2d 584
Minn. Ct. App. 2017
(-09 (Minn. 1997)), review denied (Minn. Feb.
- State of Minnesota v. Xa Vang Minn. Ct. App. 2016
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State of Minnesota v. Xa Vang
Minn. Ct. App. 2016
“[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 12 cross-examination about the statement.” -09 (Minn. App. 2000) (citing Minn. R. Evid.
- State of Minnesota v. Tetyang Puok Juate-Yout Minn. Ct. App. 2016
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State of Minnesota v. Tetyang Puok Juate-Yout
Minn. Ct. App. 2016
“[A] witness’s prior statement that is consistent with [her] trial testimony is admissible as nonhearsay evidence if the statement is helpful to 3 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) (citing Minn. R. Evid.
- Gary Cornelius Whitehurst v. State of Minnesota Minn. Ct. App. 2016
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Gary Cornelius Whitehurst v. State of Minnesota
Minn. Ct. App. 2016
-48 (Minn. 2004); review denied (Minn. Feb.
- State of Minnesota v. Brian James Liimatta Minn. Ct. App. 2015
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State of Minnesota v. Brian James Liimatta
Minn. Ct. App. 2015
“[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) (citing Minn. R. Evid.
- State of Minnesota v. Thomas James Mitchell Minn. Ct. App. 2015
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State of Minnesota v. Thomas James Mitchell
Minn. Ct. App. 2015
review denied (Minn. Feb.
- In the Matter of the Welfare of: P. J. K., Child. Minn. Ct. App. 2015
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In the Matter of the Welfare of: P. J. K., Child.
Minn. Ct. App. 2015
Under that rule, “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, 5 –09 (Minn. App. 2000), review denied (Minn. Feb.
- State of Minnesota v. Jose Luis Guzman Minn. Ct. App. 2015
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State of Minnesota v. Jose Luis Guzman
Minn. Ct. App. 2015
Under rule 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 8 the statement.” review denied (Minn. Feb.
- State of Minnesota v. Albert Michael Openshaw Minn. Ct. App. 2015
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State of Minnesota v. Albert Michael Openshaw
Minn. Ct. App. 2015
801(d)(1)(B), a witness’s prior statement that is consistent with her testimony at trial “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 4 testifies at trial and is subject to cross-examination about the statement.” -09 (Minn. App. 2000), review denied (Minn. Feb.
- State of Minnesota v. Tyrone Joseph Mohr Minn. Ct. App. 2014
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State of Minnesota v. Tyrone Joseph Mohr
Minn. Ct. App. 2014
review denied (Minn. Feb.
- State of Minnesota v. Christopher Steven Pettinelli Minn. Ct. App. 2014
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State of Minnesota v. Christopher Steven Pettinelli
Minn. Ct. App. 2014
(“Inconsistencies in testimony and conflicts in evidence .
- State of Minnesota v. John Joseph Lynch Minn. Ct. App. 2014
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State of Minnesota v. John Joseph Lynch
Minn. Ct. App. 2014
review denied (Minn. Feb.
- State v. Zulu 706 N.W.2d 919 Minn. Ct. App. 2005
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State v. Zulu
706 N.W.2d 919
Minn. Ct. App. 2005
“[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.” review denied (Minn. Feb.
- State v. Hearn 647 N.W.2d 27 Minn. Ct. App. 2002
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State v. Hearn
647 N.W.2d 27
Minn. Ct. App. 2002
(citation omitted), review denied (Minn. Feb.
- In the Welfare of T.N.Y. 632 N.W.2d 765 Minn. Ct. App. 2001
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In the Welfare of T.N.Y.
632 N.W.2d 765
Minn. Ct. App. 2001
(citations omitted), review denied (Minn. Feb.