Cited by

Opinions in Minnesota that cite In Re the Welfare of S.A.M., 570 N.W.2d 162.

33 citing documents.

State of Minnesota v. Richard Charles Graves Minn. Ct. App. 2026
See 11 (describing witness testimony as the “conventional method for authenticating photos” and stating that a photograph “is thought to be a pictorial representation of what the witness observed”).
State of Minnesota v. Adam Hassan Yusuf Minn. Ct. App. 2026
-66 (Minn. App. 1997); see 10 Minn. R. Evid.
James A. Nilsson v. Jeannie Ball, Jennifer Jean Ball Minn. Ct. App. 2026
trials is governed by Rule 901 of the Minnesota Rules of Evidence.” Minn. R. Evid.
State of Minnesota v. Anthony James Cox 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.”
State of Minnesota v. Anthony Jabri Santos 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 v. Jill Diane Tucker Minn. Ct. App. 2025
State of Minnesota v. Amal Mohamed Osman 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.”
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).
State of Minnesota v. Steven Douglas Nelson Minn. Ct. App. 2023
901(b)(9); - 67 (Minn. App. 1997) (affirming admission of surveillance video-recording).
State of Minnesota v. Almanzo Ousley Cotton Minn. Ct. App. 2023
State of Minnesota v. Ronald James Cartharn 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 v. Keijuan Jarqaway Antonio Brown Minn. Ct. App. 2021
Theodore Pierre Jerry v. State of Minnesota Minn. Ct. App. 2019
State of Minnesota v. Charles Edward Love 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 v. Wilmer Govani Montoya Ulloa Minn. Ct. App. 2017
In re the Estate of: Harold E. Farnes, a/k/a Harold Farnes and Harold Ellwood Farnes, Deceased Minn. Ct. App. 2016
In re the Estate of: Harold E. Farnes, a/k/a Harold Farnes and Harold Ellwood Farnes, Deceased 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
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
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
In Re Jrm 653 N.W.2d 207 Minn. Ct. App. 2002
(applying same standard to juvenile cases).
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