Cited by
Opinions in Minnesota that cite State v. Patterson, 577 N.W.2d 494.
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State of Minnesota, Respondent,
Minn. Ct. App. 2026
(stating that vouching occurs “when the government implies a guarantee of a witness’ s truthfulness, refers to facts outside the record, or expresses a personal opinion as to a witness’s credibility”).
- State of Minnesota, Respondent, Minn. Ct. App. 2026
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State of Minnesota, Respondent,
Minn. Ct. App. 2026
Vouching occurs “when the government implies a guarantee of a witness’s truthfulness, refers to facts outside the record, or expresses a personal opinion as to a witness’s credibility.” (quotation omitted).
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State of Minnesota, Respondent,
Minn. Ct. App. 2026
gues that the prosecutor belittled his chosen defense, deviating from the rule that the prosecutor must not “denigrate a particular type of defense, either explicitly or in the abstract.” Vouching occurs “when the government implies a guarantee of a witness’s truthfulness, refers to facts outside the record, or expresses a personal opinion as to a witness’s credibility.” -98 (Minn. 1998) (quoting United States v. Beasley, 102 F.3d 1440, 1449 (8th Cir. 1996)).
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State of Minnesota, Respondent,
Minn. Ct. App. 2023
But here, Rock does not show error as the statements he points to do not “impl[y] a guarantee of a witness’s truthfulness, refer[] to facts outside the record, or express[] a personal opinion as to a witness’s credibility.”
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State of Minnesota, Respondent,
Minn. Ct. App. 2023
“[ V]ouching occurs when the government implies a guarantee of a witness’ s truthfulness, refers to facts outside the record, or 9 expresses a personal opinion as to a witness’s credibility.” d 494, 497 (Minn. 1998) (quotation omitted).
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State of Minnesota, Respondent,
Minn. Ct. App. 2022
-98 (Minn. 1998); (stating that a prosecutor commits misconduct when they “personally endorse the credibility of witnesses”).
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State of Minnesota, Respondent,
Minn. Ct. App. 2022
or expresses a personal opinion as to a witness’s credibility.’” d 131, 139 (Minn. App. 2012) (), rev. denied (Minn. Mar.
- State of Minnesota, Respondent, vs. Martell Antonio Bloxson, Appellant. Minn. Ct. App. 2021
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State of Minnesota, Respondent,
Minn. Ct. App. 2021
He said, she seemed—he believed her.” Vouching occurs when “the [prosecuto r] implies a guarantee of a witness’s truthfulness, refers to facts outside the reco rd, or expresses a personal opinion as to a witness’s credibility.” State v. Patterson , (quotation omitted).
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State of Minnesota, Respondent,
Minn. Ct. App. 2021
(citing United States v. Tate , 915 F.2d 400, 401 (8th Cir. 1990)).
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State of Minnesota, Respondent,
Minn. Ct. App. 2021
or expresses a personal opinion as to a witness’s credibility.” (quotation omitted).
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State of Minnesota, Respondent,
Minn. Ct. App. 2020
State v. Patterson , (quo tation omitted).
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State of Minnesota, Respondent,
Minn. Ct. App. 2019
But it is error to guarantee a witness’s truthfulness or express a “personal opinion as to a witness’s credibility.” d 494, 497 (Minn. 1998) (quotation omitted).
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State of Minnesota, Respondent,
Minn. Ct. App. 2019
( vouching occurs when state refers to facts outside record when arguing for witness credibility).
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State of Minnesota, Respondent,
Minn. Ct. App. 2019
expresses a personal opinion as to a witness’s credibility.” (quotation omitted); (finding prosecutorial misconduct when prosecutor referred to a defense witness named “Lyra” as aptly named).
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State of Minnesota, Respondent,
Minn. Ct. App. 2019
” (d 494, 497 (Minn. 1998)).
- State of Minnesota, Respondent, Minn. Ct. App. 2018
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A16-1804
Minn. Ct. App. 2017
Vouching occurs “when the government implies a guarantee of a witness’s truthfulness, refers to facts outside the reco rd, or expresses a personal opinion as to a witness’s credibility.” (quotation omitted).
- State of Minnesota v. Joshua Williams Wermers Minn. Ct. App. 2016
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State of Minnesota v. Joshua Williams Wermers
Minn. Ct. App. 2016
But vouching occurs when a prosecutor “implies a guarantee of a witness’s truthfulness, refers to facts outside the record, or expresses a personal opinion as to a witness’s credibility.”
- State of Minnesota v. Blake Adam Schneider Minn. Ct. App. 2016
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State of Minnesota v. Blake Adam Schneider
Minn. Ct. App. 2016
Vouching occurs “when the government implies a guarantee of a witness’s truthfulness, refers to facts outside the record, or expresses a personal opinion as to a witness’s credibility.” (quotation omitted).
- State of Minnesota v. Erick Robert Gordon Minn. Ct. App. 2015
- State of Minnesota v. Erick Robert Gordon Minn. Ct. App. 2015
- State of Minnesota v. Michael Arthur Boelz Minn. Ct. App. 2014
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State of Minnesota v. Michael Arthur Boelz
Minn. Ct. App. 2014
A prosecutor commits misconduct if he or she “implies a guarantee of a witness’s truthfulness, refers to facts outside the record, or expresses a personal opinion as to a witness’s credibility.” (quotation omitted).
- State of Minnesota v. Dontrell Dyna Flowers Minn. Ct. App. 2014
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State of Minnesota v. Dontrell Dyna Flowers
Minn. Ct. App. 2014
But, during closing arguments, a prosecutor may properly present arguments about why particular witnesses should be perceived as credible or incredible so long as he 14 does not “impl[y] a guarantee of a witness’s truthfulness, refer[] to facts outside the record, or express[] a personal opinion as to a witness’s credibility.” (quotation omitted).
- State v. Smith 825 N.W.2d 131 Minn. Ct. App. 2012
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State v. Smith
825 N.W.2d 131
Minn. Ct. App. 2012
A prosecutor’s statements in closing argument become improper vouching when the prosecutor “implies a guarantee of a witness’s truthfulness, refers to facts outside the record, or expresses a personal opinion as to a witness’s credibility.” (quotation omitted).
- State v. Jackson 773 N.W.2d 111 Minn. 2009
- State v. Martin 773 N.W.2d 89 Minn. 2009
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State v. Jackson
773 N.W.2d 111
Minn. 2009
Prosecu-torial misconduct occurs “when the [prosecutor] implies a guarantee of a witness’s truthfulness, refers to facts outside the record, or expresses a personal opinion as to a witness’s credibility.” (quoting United States v. Beasley, 102 F.3d 1440, 1449 (8th Cir.1996)).
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State v. Martin
773 N.W.2d 89
Minn. 2009
Prosecu-torial misconduct occurs “when the [prosecutor] implies a guarantee of a witness’s truthfulness, refers to facts outside the record, or expresses a personal opinion as to a witness’s credibility.” (quoting United States v. Beasley, 102 F.3d 1440, 1449 (8th Cir.1996)).
- State v. Rucker 752 N.W.2d 538 Minn. Ct. App. 2008
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State v. Rucker
752 N.W.2d 538
Minn. Ct. App. 2008
“[V]ouching occurs when the government implies a guarantee of a witness’s truthfulness, refers to facts outside the record, or expresses a personal opinion as to a witness’s credibility.” (quotation omitted).
- State v. Outlaw 748 N.W.2d 349 Minn. Ct. App. 2008
- State v. Outlaw 748 N.W.2d 349 Minn. Ct. App. 2008
- State v. Jackson 714 N.W.2d 681 Minn. 2006
- In Re the Welfare of D.D.R. 713 N.W.2d 891 Minn. Ct. App. 2006
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In Re the Welfare of D.D.R.
713 N.W.2d 891
Minn. Ct. App. 2006
Vouching occurs “when the government implies a guarantee of a witness’s truthfulness, refers to facts outside the record, or expresses a personal opinion as to a witness’s credibility.” (quoting United States v. Beasley, 102 F.3d 1440, 1449 (8th Cir.1996)).
- State v. Lopez-Rios 669 N.W.2d 603 Minn. 2003
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State v. Lopez-Rios
669 N.W.2d 603
Minn. 2003
As for vouching, that occurs “ “when the government implies a guarantee of a witness’s truthfulness, refers to facts outside the record, or expresses a personal opinion as to a witness’s credibility.’ ” (quoting United States v. Beasley, 102 F.3d 1440, 1449 (8th Cir.1996)).
- State v. Folkers 581 N.W.2d 321 Minn. 1998
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State v. Folkers
581 N.W.2d 321
Minn. 1998
Finally, specifically in response to a similar claim of vouching, that evidence of the terms of a *326 witness’ plea agreement does not constitute improper vouching when it includes a truth-ftdness provision, unless the state directly or by implication expresses an opinion as to the witness’ credibility.