Cited by
Opinions in Minnesota that cite In Re the Welfare of S.A.M., 570 N.W.2d 162.
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State of Minnesota v. Adam Hassan Yusuf
Minn. Ct. App. 2026
-66 (Minn. App. 1997); see 10 Minn. R. Evid.
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James A. Nilsson, Respondent,
Minn. Ct. App. 2026
trials is governed by Rule 901 of the Minnesota Rules of Evidence.” Minn. R. Evid.
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State of Minnesota, Respondent,
Minn. Ct. App. 2025
We have applied this rule to video evidence, holding that videos “may be authenticated by testimony describing the reliability of the process or system that created the tape” or by “testimony from an observer that the videotape is an accurate portrayal of the event, if the evidence sufficiently demonstrates that the videotape is what its proponent claims.”
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State of Minnesota, Respondent,
Minn. Ct. App. 2025
d 889, 893 (Minn. App. 1986) (concluding testimony of security guard who watched football game was sufficient to authenticate video of the game).
- State of Minnesota, Respondent, Minn. Ct. App. 2025
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State of Minnesota, Respondent,
Minn. Ct. App. 2025
Video evidence can be authenticated either “by testimony describing the reliability of the process or system that created [it],” or “by testimony from an observer that the video[] is an accurate portrayal of the event, if the evidence sufficiently demonstrates that the video[] is what its proponent claims.”
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In the Matter of the Welfare of: L. L. I., Child.
Minn. Ct. App. 2024
(applying this standard of review to a juvenile-delinquency proceeding).
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State of Minnesota, Respondent,
Minn. Ct. App. 2023
901(b)(9); - 67 (Minn. App. 1997) (affirming admission of surveillance video-recording).
- State of Minnesota, Respondent, Minn. Ct. App. 2023
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State of Minnesota, Respondent,
Minn. Ct. App. 2021
-67 (Minn. App. 1997), we concluded that the foundational elements did not apply to a video recording, noting that video recordings are inherently more reliable than audio recordings.
- State of Minnesota, Respondent, Minn. Ct. App. 2021
- Theodore Pierre Jerry, petitioner, Appellant, Minn. Ct. App. 2019
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State of Minnesota, Respondent,
Minn. Ct. App. 2018
Video recordings may be authenticated in two ways, using the “pictorial witness theory” or the “silent witness theory.” -65 (Minn. App. 1997).
- State v. Winbush 912 N.W.2d 678 Minn. Ct. App. 2018
- State v. Winbush 912 N.W.2d 678 Minn. Ct. App. 2018
- State of Minnesota, Respondent, Minn. Ct. App. 2017
- In re the Estate of: Harold E. Farnes, a/k/a Harold Farnes and Harold Ellwood Farnes Minn. Ct. App. 2016
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In re the Estate of: Harold E. Farnes, a/k/a Harold Farnes and Harold Ellwood Farnes
Minn. Ct. App. 2016
“The evidentiary requirement for authentication as a condition precedent to admissibility is met only if the evidence is ‘sufficient to support a finding that the matter in question is what its proponent claims.’” (quoting Minn. R. Evid.
- State of Minnesota v. Jean Clarice Clement Minn. Ct. App. 2015
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State of Minnesota v. Jean Clarice Clement
Minn. Ct. App. 2015
-65 (Minn. App. 1997); see Minn. R. Evid.
- In the Matter of the Welfare of: J. C. A., Jr., Child. Minn. Ct. App. 2014
- In the Matter of the Welfare of: J. C. A., Jr., Child. Minn. Ct. App. 2014
- In the Matter of the Welfare of: G. A. H., Child. Minn. Ct. App. 2014
- In the Matter of the Welfare of: G. A. H., Child. Minn. Ct. App. 2014
- State of Minnesota v. Charles Edward Love Minn. Ct. App. 2014
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State of Minnesota v. Charles Edward Love
Minn. Ct. App. 2014
if the evidence sufficiently demonstrates that the videotape is what its proponent claims.” d 162, 166 (Minn. App. 1997).
- In re the Welfare of J.R.M. 653 N.W.2d 207 Minn. Ct. App. 2002
- In Re Jrm 653 N.W.2d 207 Minn. Ct. App. 2002
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In Re Jrm
653 N.W.2d 207
Minn. Ct. App. 2002
(applying same standard to juvenile cases).
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In re the Welfare of J.R.M.
653 N.W.2d 207
Minn. Ct. App. 2002
(applying same standard to juvenile cases).
- In Re the Welfare of S.S.E. 629 N.W.2d 456 Minn. Ct. App. 2001
- In Re the Welfare of S.S.E. 629 N.W.2d 456 Minn. Ct. App. 2001