Cited by

In Minnesota, “evidence of prior bad acts and previously committed crimes is commonly known as Spreigl evidence.”

11, 2001) ; (concluding that a defendant was under arrest after an offic er handcuffed him, “led him to the squad car and searched him”).

“The existence of probable cause depends on the facts of each individual case.” -99 (Minn. 1993).

“Whether the arresting officer’s actions were reasonable is an objective inquiry,” and “[t]he existence of probable cause depends on the facts of each individual case.” -99 (Minn. 1993).

d 593, 598-99 (Minn. 1993).

In general, “[w]hether the arresting officer’s actions were reasonable is an objective inquiry,” and “[t]he existence of probable cause depends on the facts of each individual case.”

d 593, 598-99 (Minn. 1993).

(“Spreigl evidence need not be identical in every way to the charged crime.”); d 593, 603 (Minn. 1993) (noting that consistency of injuries helps demonstrate common 9 modus operandi).

The test for probable cause is “[w]hether the officers in the particular circumstances, conditioned by their own observations and information and guided by the whole of their police experience, reasonably could have believed that a crime had been committed by the 7 person to be arrested.” (quotation omitted).

(noting “appellant was probably not hurt by the introduction of his prior conviction [for impeachment] .

See, -67 (Minn.1993); -47 (Minn.1984).

Riley, d at 526 ; (concluding that defendant’s statement was voluntary even though police lied to him about the evidence, in part, because there were no threats or physical intimidation involved).

hat a surveillance tape recorded his illegal actions when in fact no such tape existed, and that when police officers realized their mistake they did not inform defendant); (holding that the use of trickery and deception by law enforcement agents is to be considered when determining the admissibility of a subsequent confession); , 598 n. 3 (Minn.1993) (noting that a BCA Agent told appellant that certain evidence linked appellant to the murder when, in fact, no such evidence existed).

lom to DJ’s Expressway, witnesses other than Hanek were not able to identify Blom at the lineup, and the defense planned to introduce its own expert testimony to establish that the tooth found on Blom’s property could not be Poirier’s. Further, we have held that where identity is at issue and the defendant offers an alibi, “the state may buttress its case with Spreigl evidence.”

604-05 n. 6 (Minn.1993) (citing Estelle, 502 U.S. at 72 n. 4).

at 810 (declining to adopt a per se rule of exclusion, but cautioning police that they proceed at their own risk when they use deception); (holding that officer’s false statement to suspect during interrogation did not make confession involuntary where interrogating officers used no threats or intimidation, defendant had experience in criminal-justice system, and defendant was of sufficient age and intelligence to understand situation in

See, (person under arrest and therefore in custody when handcuffed); (concluding that an officer telling suspect he was “under arrest” indicated custody), review denied (Minn. Dec.

See, e.g., United States v. Griffin, 922 F.2d 1343, 1349 (8th Cir.1990) (discussing factors indicating custody, including being told under arrest); (person under arrest when handcuffed).

ANALYSIS “[Ejvidence of prior bad acts and previously committed crimes is commonly known as Spreigl evidence.”

see generally State v. Spreigl, 272 Minn. 488