Cited by
Opinions in Minnesota that cite State v. DeBaere, 356 N.W.2d 301.
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State of Minnesota, Respondent,
Minn. Ct. App. 2025
To determine whether Spreigl evidence is relevant, a district court generally should consider, among other things, “whether there is a sufficiently close relationship between the charged offense and the Spreigl offense in time, place, or modus operandi.” see also Ness, d at 688.
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State of Minnesota, Respondent,
Minn. Ct. App. 2025
To determine whether Spreigl evidence is relevant, a district court generally should consider, among other things, “whether there is a sufficiently close relationship between the charged offense and the Spreigl offense in time, place, or modus operandi.” , 305 (Minn. 1984)
- State of Minnesota v. Peter Joseph Nayquonabe Minn. Ct. App. 2024
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State of Minnesota v. Peter Joseph Nayquonabe
Minn. Ct. App. 2024
See, –39 (Minn. 2004) (citing Ani’s possibility statement but affirming the conviction based only on victim’s uncorroborated testimony); (citing the Ani statement, noting the presence of corroborating evidence, and concluding, “this is not such a case”); (affirming conviction based on corroborated testimony); –40 (Minn. 1983) (same); (same); (same); –95 (Minn. 1982) (sam
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State of Minnesota, Respondent,
Minn. Ct. App. 2023
mean[s] a situation in which a complainant has been physically attacked or has emerged from the incident so shaken or traumatized that no reasonable person would believe the complainant desired that particular sexual contact.” (), rev. denied (Minn. Oct.
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State of Minnesota, Respondent,
Minn. Ct. App. 2023
Although the evidence was not initially admitted to prove lack of consent but rather the identity of A.D.’s attacker, the supreme court has recognized that, if the victim’s consent is at issue in a sexual-assault case, “other-crime evidence show[ing] a pattern of similar aggressive sexual behavior by defendant against other women in the community” is “highly relevant,” and Buckles ultimately testified that he had consensual sex with A.D.
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State of Minnesota, Respondent,
Minn. Ct. App. 2023
To determine whether Spreigl evidence is relevant, a district court “should consider the issues in the case, the reasons and need for the evidence, and whether there is a sufficiently close relationship between the charged offense and the Spreigl offense in time, place, or modus operandi.”
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State of Minnesota, Respondent,
Minn. Ct. App. 2022
See State v. DeBaere , (holding that similarit ies in “aggressive sexual behavior” between prior attempted sexual assaults and actual sexual assault rendered rule 404(b) e vidence admissible).
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State of Minnesota, Respondent,
Minn. Ct. App. 2022
See S (stating that where a defendant asserts a consent defense in a sexual-assault case, “other-crime evidence show[ing] a pattern of similar aggressive sexual behavior by defendant against other women in the community .
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State of Minnesota, Respondent,
Minn. Ct. App. 2019
See Clark, d at 316 (stating that, in sexual-assault prosecutions, Spreigl evidence may be introduced to establish, “by showing a common scheme or plan ,” that the sexual act occurred); d 301, 305 (Minn. 1984) (recognizing that Spreigl evidence may be “relevant to the issue of consent”).
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State of Minnesota, Respondent,
Minn. Ct. App. 2018
Further, the Minnesota Supreme Court has held that Spreigl evidence is admissible and “highly relevant to the issue of consent” in a cr iminal sexual conduct case when the evidence “showed a pattern of similar aggressive se xual behavior by [the] defendan t against other women in the community.”
- State of Minnesota v. Demarcus Nasson Chaney Minn. Ct. App. 2015
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State of Minnesota v. Demarcus Nasson Chaney
Minn. Ct. App. 2015
Where the issue is a victim’s consent in a sexual-assault case, “other-crime evidence show[ing] a pattern of similar aggressive sexual behavior by defendant against other women in the community” is “highly relevant.”
- Carlton v. State 816 N.W.2d 590 Minn. 2012
- Carlton v. State 816 N.W.2d 590 Minn. 2012
- State v. Cao 788 N.W.2d 710 Minn. 2010
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State v. Cao
788 N.W.2d 710
Minn. 2010
(noting that a complainant’s prompt police report and “distraught condition” in talking with police was corroborative of sexual assault).
- State v. Leutschaft 759 N.W.2d 414 Minn. Ct. App. 2009
- State v. Leutschaft 759 N.W.2d 414 Minn. Ct. App. 2009
- In re the Welfare of A.A.M. 684 N.W.2d 925 Minn. Ct. App. 2004
- In Re Aam 684 N.W.2d 925 Minn. Ct. App. 2004
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In re the Welfare of A.A.M.
684 N.W.2d 925
Minn. Ct. App. 2004
(finding that injury to complainant was proof of her nonconsent).
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In Re Aam
684 N.W.2d 925
Minn. Ct. App. 2004
(finding that injury to complainant was proof of her nonconsent).
- State v. Blom 682 N.W.2d 578 Minn. 2004
- State v. Blom 682 N.W.2d 578 Minn. 2004
- Ture v. State 681 N.W.2d 9 Minn. 2004
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Ture v. State
681 N.W.2d 9
Minn. 2004
To determine the relevance of such evidence, a district court should consider “the issues in the case, the reasons and need for the evidence, and whether there is a sufficiently close relationship between the charged offense and the Spreigl offense in time, place, or mo-dus operandi.”
- Pierson v. State 637 N.W.2d 571 Minn. 2002
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Pierson v. State
637 N.W.2d 571
Minn. 2002
“In determining the relevance and materiality of Spreigl evidence, ‘the trial court should consider the issues in the case, the reasons and need for the evidence, and whether there is a sufficiently close relationship between the charged offense and the Spreigl offense in time, place, or modus operandi.’ ” ().
- State v. Jackson 615 N.W.2d 391 Minn. Ct. App. 2000
- State v. Jackson 615 N.W.2d 391 Minn. Ct. App. 2000
- State v. Lynch 590 N.W.2d 75 Minn. 1999
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State v. Lynch
590 N.W.2d 75
Minn. 1999
In determining the relevance and materiality of Spreigl evidence, “the trial court should consider the issues in the case, the reasons and need for the evidence, and whether there is a sufficiently close relationship between the charged offense and the Spreigl offense in time, place, or modus operands”
- State v. Kennedy 585 N.W.2d 385 Minn. 1998
- State v. Kennedy 585 N.W.2d 385 Minn. 1998
- M.L. v. Magnuson 531 N.W.2d 849 Minn. Ct. App. 1995
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M.L. v. Magnuson
531 N.W.2d 849
Minn. Ct. App. 1995
(evidence of other assaultive behavior admissible where defendant claimed self-defense and intoxication); (evidence of other sexually assaultive behavior admissible where defendant claimed intercourse was consensual); pet.
- State v. Maurer 488 N.W.2d 834 Minn. Ct. App. 1992
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State v. Maurer
488 N.W.2d 834
Minn. Ct. App. 1992
-05 (Minn.1984) (pattern of sexually aggressive behavior was admissible where consent was the defense).
- State v. Cichon 458 N.W.2d 730 Minn. Ct. App. 1990
- State v. Cichon 458 N.W.2d 730 Minn. Ct. App. 1990
- State v. Drieman 457 N.W.2d 703 Minn. 1990
- State v. Drieman 457 N.W.2d 703 Minn. 1990
- State v. Totimeh 433 N.W.2d 921 Minn. Ct. App. 1988
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State v. Totimeh
433 N.W.2d 921
Minn. Ct. App. 1988
Further, appellant’s entry with intent to commit criminal sexual conduct “was inferable from the evidence of his assaultive conduct once inside.”
- State v. Rainer 411 N.W.2d 490 Minn. 1987
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State v. Rainer
411 N.W.2d 490
Minn. 1987
This court has held, for example, that a wife’s earlier threats against her husband, whom she later allegedly killed, were admissible to show intent and absence of mistake, State v. Diamond, 308 Minn. at 448 , d at 99 , and that a pattern of aggressive sexual behavior against women in the community by an accused rapist was admissible on the issue of consent
- State v. Lau 409 N.W.2d 275 Minn. Ct. App. 1987
- State v. Lau 409 N.W.2d 275 Minn. Ct. App. 1987
- State v. Okegbenro 409 N.W.2d 1 Minn. Ct. App. 1987