Cited by

(determining that the jury did not unduly focus on the wrongfully admitted evidence when the trial included “extensive testimony regarding DNA, ballistics, and an arson investigation” and when the wrongful evidence “was not the focus of any one witness’ testimony”); Trifiletti, d at 95 (exp

11 conducting a harmless-error review, appellate courts “examine the entire record,” and “cannot focus only on evidence of guilt.”

In considering what effect the evidence had on the verdict, we consider factors including, “the manner in which the evidence was presented, whether it was highly persuasive, whether it was used in closing argument, and whether the defense effectively countered it.”

When conducting harmless-error review, we “examine the entire record,” Jaros, d at 474, and “cannot focus only on evidence of guilt,”

To assess the impact of improperly admitted evidence, the reviewing court considers “the manner in which the evidence was presented, whether it was highly persuasive, whether it was used in closing argument, and whether the defense effectively countered it.”

In deciding the impact of the challenged conduct, this court considers “the manner in which the evidence was presented, whether it was highly persuasive, whether it was used in closing argument, and whether the defense effectively countered it.” (hold ing that a statement did not amount to misconduct because “[t]he improper statement was only two sentences in a closing argument that amounted to over 20 transcribed pages .”); State v. Glaze , (hold

In deciding what effect erroneously admitted evidence had on the verdict, we consider “the manner in which the evidence was presented, whether it was highly persuasive, whether it was used in closing argument, and whether the defense effectively countered it.”

In deciding what effect erroneously admitted evidence had on the verdict, the reviewing court considers “the manner in which the evidence was presented, whether it was highly persuasive, whether it was used in closing 9 argument, and whether the defense effectively countered it.”

In deciding what effect challenged evidence or conduct had on the verdict, this court considers “the manner in which the evidence was presented, whether i t was highly persuasive, whether it was used in closing argument, and whether the defense effectively countered it.” Townsend v. State , (holding that a statement did not amount to misconduct because “[t]he improper statement was only two sentences in a closing argument that amounted to over 20 transcribed pages”); State v. Glaze , (hold

In deciding what effect challenged evidence or conduct had on the verdict, this court considers “the manner in which the evid ence was presented, whether it was highly persuasive, whether it was used in closing ar gument, and whether the defense effectively countered it.” Townsend v. State , (holding that a statement did not amount to misconduct because “[t]he improper statem ent was only two sent ences in a closing argument that amounted to over 20 transcribed pages”); (hol

We must “look to the basis on which the [factfinder] rested its verdict and determine what effect the error had on the actual verdict.” Townsend v. State , (citation omitted) (internal quotation marks omitted); (explaining that the harmless error analysis is “better labelled as ‘harmless error impact analysis,’ because it is the impact of that error that the appellate court must consider”).

In evaluating whether there is a reasonable likelihood that the erroneously admitted evidence significantly affected the verdict, we consider “the manner in which the evidence was presented, whether it was highly persuasive, whether it was used in closing argument, and whether the defense effectively countered it.”

In considering the effect of erroneously admitted evidence , we examine “the manner in which the evidence was presented, whether it was highly persuasive, whether it was used in closing argument, and 9 whether the defense eff ectively countered it.”

In deciding what effect erroneously admitted evide nce had on the verdict, the reviewing court considers “the manner in which the evidence was presented, whether it was highly persuasive, whether it was used in closing argument, and whether the defense effectively countered it.”

In deciding what effect the admitted evidence had on the verdict, this court considers “the manner in which the evidence was presented, whether it was highly persuasive, whether it was used in closing argument, and whether the defense effectively countered it.”

’s testimony , but rather encouraged the jury to “parse out whatever is in th at video” and “ decide whether or not you see or you don’t see a gun” which is “subject to interpretation.” Lastly, we note that “o verwhelming evidence of guilt is a factor, often a very important one, in determining whether, beyond a reasonable doubt, the error has no impact on the verdict.” Townsend v. State , .

In deciding what effect erroneously admitted evidence had on the verdict, the reviewing court considers “the manner in which the evidence was presented, whether it was highly persuasive, whether i t was used in closing argument, and whether the defense effectively countered it.”

In determining whether erroneously admitted evidence affected the verdict, we consider “the manner in wh ich the evidence was presen ted, whether it was highly persuasive, whether it was used in closing ar gument, and whether the defense effectively countered it.” Townsend v. State , (“The court’s analysis under the third prong of the plain error test is the equivalent of a harmless error analysis.”).

In determining what effect erroneously admitted evidence had on the verdict, the reviewing court considers “the manner in which the evidence was presented, whether it was highly persuasive, whether it was used in closing argument, and whether the defense effectively countered it.” Townsend v. State , see also State v. Sanders , .

however, require us to apply the constitutional harmless-error test to the erroneous admission of prior bad acts evidence.

(applying harmless-beyond-a-reasonable-doubt standard).

In evaluating prejudice, we are to consider “the manner in which the evidence was presented, whether it was highly persuasive, whether it was used in closing argument, and whether the defense effectively countered it.”

Townsend v. State (Townsend III)

If the verdict was surely unattributable to the error, the error is harmless beyond a reasonable doubt.” (citations and quotation omitted).

To determine whether the error warrants a new trial, we consider “the manner in which the evidence was presented, whether it was highly persuasive, whether it was used in closing argument, and whether the defense effectively countered it.”

See Townsend v. State (Townsend II), -29 (Minn.1998) (dismissing Townsend’s claims of alleged trial errors as procedurally barred and claim of ineffective assistance of appellate counsel as lacking support in the record); Townsend v. State (Townsend III), (concluding that the error in admitting evidence of the related attempted murder was harmless because the verdict was surely unattributable to the erroneously admitted evidence); Townsend v. State (Townsend TV), -20 (Minn.2006) (dismissing Town

On appeal, and Townsend v. State (Townsend II), which were decided after El-Shabazz’s conviction, applied a “stricter” standard for evaluating harmless error.

-23 (Minn.2002) (using harmless-error-beyond-a-reasonable-doubt standard in case that did not involve constitutional error); , 377-78 n. 2 (Minn.1999) (acknowledging discord in cases).