Cited by
Opinions in Minnesota that cite State v. Daniels, 380 N.W.2d 777.
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State of Minnesota, Respondent,
Minn. Ct. App. 2026
See Berrisford, d at 850 (affirming admission of a statement made “just 90 minutes after the murder”); -84 (Minn. 1986) (affirming admission of statements made “within an hour” of a fire).
- State of Minnesota v. Justin Bradley Camp Minn. Ct. App. 2025
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State of Minnesota v. Justin Bradley Camp
Minn. Ct. App. 2025
To be admissible, an excited utterance must meet three requirements: (1) “there must be a startling event or condition,” (2) “the statement must relate to the startling event or condition,” and (3) “the declarant must be under a sufficient aura of excitement caused by the event or condition to insure the trustworthiness of the statement.”
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State of Minnesota, Respondent,
Minn. Ct. App. 2025
Three requirements must be met for hearsay to qualify as an excited utterance: (1) there was a startling event or condition; (2) the hearsay statement relates to the startling event or condition; and (3) the declarant was “under a sufficient aura of excitement caused by the event or condition to insure the trustworthiness of the statement.” (quoting Minn. R. Evid.
- State of Minnesota v. Jerome Anthony Woodland Minn. Ct. App. 2024
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State of Minnesota v. Jerome Anthony Woodland
Minn. Ct. App. 2024
y prohibition exists for “[a] statement relating to a startling event or condition made while the declarant was under the stress of excitement caused by the event or condition.” The rationale for the exception “stems from the belief that the excitement caused by the event eliminates the possibility of conscious fabrication, and insures the trustworthiness of the statement.” (quoting Minn. R. Evid.
- State of Minnesota v. Daryl Shannon Williams Minn. Ct. App. 2024
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State of Minnesota v. Daryl Shannon Williams
Minn. Ct. App. 2024
g to a startling event or condition made while the declarant was under the stress of excitement caused by the event or condition.” The rationale for the 7 exception “stems from the belief that the excitement caused by the event eliminates the possibility of conscious fabrication, and insures the trustworthiness of the statement.” (quoting Minn. R. Evid.
- State of Minnesota, Respondent, Minn. Ct. App. 2023
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State of Minnesota, Respondent,
Minn. Ct. App. 2023
To be admissible, “three requirements must be met: (1) there must be a startling event or condition; (2) the statement must relate to the startling event or condition; and (3) the declarant must be under a sufficient aura of excitement caused by the event or condition to insure the trustworthiness of the statement.”
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Minn. 2023
d 846, 850 (Minn. 1985) (deferring to the district court’s determination that the declarant was 9 under a sufficient aura of excitement); –84 (Minn. 1986) (same).
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State of Minnesota, Respondent,
Minn. Ct. App. 2023
Such a statement must meet three requirements: (1) “there must be a startling event or condition,” (2) “the statement must relate to the startling event or condition,” and (3) “the declarant must be under a sufficient aura of excitement caused by the event or condition to [e]nsure the trustworthiness of the statement.” 1 St.
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State of Minnesota, Respondent,
Minn. Ct. App. 2022
To be admissible as an excited utterance, a statement must meet three requirements: (1) “there must be a startling event or condition,” (2) “the statement must relate to the startling event or condition,” and (3) “the declarant must be under a sufficient aura of excitement caused by the event or condition to [e]nsure the trustworthiness of the statement.” State v. Daniels , (quoting Minn. R. Evid.
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State of Minnesota, Respondent,
Minn. Ct. App. 2022
second argument, a hearsay statement qualifies as an excited utterance when three requirements are met: “(1) there must be a startling event or condition; (2) the statement must relate to the startling event or condition; and (3) the declarant must be under a sufficient aura of excitement caused by the event or condition to [e]nsure the trustworthiness of the statement.” State v. Daniels , .
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State of Minnesota, Respondent,
Minn. Ct. App. 2022
To be admissible as an excited utterance, a statement must meet three requirements: (1) “there must be a startling event or condition,” (2) “the statement must relate to the startling event or condition,” and (3) “the declarant must be under a sufficient aura of excitement caused by the event or condition to insure the trustworthiness of the statement.” (quoting Minn. R. Evid.
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State of Minnesota, Respondent,
Minn. Ct. App. 2022
To be admissible, an excited utterance must meet three requirements: (1) “there must be a startling event or condition”; (2) “the statement must relate to the startling event or condition”; and (3) “the declarant must be under a sufficient aura of excitement caused by the event or condition to insure the trustworthiness of the statement.”
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State of Minnesota, Appellant,
Minn. Ct. App. 2022
To be admissible, an excited utterance must meet three requirements: (1) “there must be a startling event or condition ;” (2) “the statement must relate to the startling event or condition;” and (3) “the declarant must be under a sufficient aura of excitement caused by the event or condition to insure the trustworthiness of the statement.”
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State of Minnesota, Respondent,
Minn. Ct. App. 2022
See State v. Berrisford , (affirming the admission of a statement made “just 90 minutes after the murder”); -84 (Minn. 1986) (affirming the admission of statements made “within an hour” of a fire).
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State of Minnesota, Respondent,
Minn. Ct. App. 2021
9 aura of excitement caused by the event or condition to insu re the trustworthiness of the statement.” State v. Daniels
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State of Minnesota, Respondent,
Minn. Ct. App. 2020
A statement is admissible as an excited utterance if: (1) there was “a startling event or condition,” (2) the statement related to the startling event or condition, and (3) “the declarant [was] under a sufficient aura of excitement c aused by the event or condition to insure the trustworthiness of the statement.”
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State of Minnesota, Respondent,
Minn. Ct. App. 2020
A statement is admissible as an excited utterance if (1) there was “a startling event or condition ,” (2) the statement relate d to the startling event or condition , and (3) “the declarant [was] under a sufficient aura of excitement caused by the event or condition to insure the trustworthiness of the statement.” (quotation omitted).
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State of Minnesota, Respondent,
Minn. Ct. App. 2019
The rationale for the excited - utterance exception “stems from the belief that the excitement caused by the event eliminates the possibility of conscious fabrication, and insures the trustworthiness of the statement.”
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State of Minnesota, Respondent,
Minn. Ct. App. 2019
To qualify as an excited utt erance, a declarant’s statement must satisfy three requirements: “(1) there must be a startling event or condition; (2) the statement must relate to the startling event or condition; and (3) the declarant must be under a sufficient aura of excitement caused by the condition to ensure the trustworthiness of the statement.” (quotation omitted).
- State of Minnesota, Respondent, Minn. Ct. App. 2018
- State of Minnesota, Respondent, Minn. Ct. App. 2018
- State of Minnesota, Respondent, Minn. Ct. App. 2017
- State of Minnesota v. Edward Antonio Zappa Minn. Ct. App. 2017
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State of Minnesota v. Edward Antonio Zappa
Minn. Ct. App. 2017
“The rationale [for this exception] stems from the belief that the excitement caused by the event eliminates the possibility of conscious fabrication, and insures the trustworthiness of the statement.” (quotation omitted).
- State of Minnesota v. Tommy William Mix Minn. Ct. App. 2016
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State of Minnesota v. Tommy William Mix
Minn. Ct. App. 2016
See, e.g., State v. Daniels, CS-2
- State of Minnesota v. Chevaze Darrell Ward Minn. Ct. App. 2016
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State of Minnesota v. Chevaze Darrell Ward
Minn. Ct. App. 2016
“The rationale [for the excited- utterance exception] stems from the belief that the excitement caused by the event eliminates the possibility of conscious fabrication, and insures the trustworthiness of the statement.” (quotation omitted).
- State of Minnesota v. Jorge Roman Vasquez Minn. Ct. App. 2016
- State of Minnesota v. Jorge Roman Vasquez Minn. Ct. App. 2016
- State of Minnesota v. Eric Jamison Brewer Minn. Ct. App. 2016
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State of Minnesota v. Eric Jamison Brewer
Minn. Ct. App. 2016
Relevant factors for determining whether a statement qualifies as an excited utterance include “‘the length of time elapsed, the nature of the event, the physical condition of the declarant, any 4 possible motive to falsify, etc.’” –83 (Minn. 1986) (quoting Minn. R. Evid.
- State of Minnesota v. Wendell Anthony Greene Minn. Ct. App. 2015
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State of Minnesota v. Wendell Anthony Greene
Minn. Ct. App. 2015
(“If the hearsay statements .
- State of Minnesota v. Leland Ronald Nelson, II Minn. Ct. App. 2015
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State of Minnesota v. Leland Ronald Nelson, II
Minn. Ct. App. 2015
was under the stress of excitement when she made the statements to Larson, which “eliminates the possibility of conscious fabrication, and insures the trustworthiness of the statement.”
- State of Minnesota v. George Matthews Minn. Ct. App. 2015
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State of Minnesota v. George Matthews
Minn. Ct. App. 2015
“The rationale [for the exception] stems from the belief that the excitement caused by the event eliminates the possibility of conscious fabrication, and insures the trustworthiness of the statement.” 4 (Minn. 1986).
- State of Minnesota v. Michael Robert Dotterweich Minn. Ct. App. 2014
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State of Minnesota v. Michael Robert Dotterweich
Minn. Ct. App. 2014
Such a statement must be made under the “aura of excitement caused by the event or condition to insure the trustworthiness of the statement.”
- State of Minnesota v. Corey Lee Melde Minn. Ct. App. 2014
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State of Minnesota v. Corey Lee Melde
Minn. Ct. App. 2014
The district court must consider all relevant circumstances including “the length of time elapsed, the nature of the event, the physical condition of the declarant, [and] any possible motive to falsify.” -83 (Minn. 1986) (quotation omitted).
- State v. Hogetvedt 623 N.W.2d 909 Minn. Ct. App. 2001
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State v. Hogetvedt
623 N.W.2d 909
Minn. Ct. App. 2001
Relevant factors in determining whether an out-of-court statement qualifies as an excited utterance include “the length of time elapsed, the nature of the event, the physical condition of the declar-ant, and any possible motive to falsify.” -83 (Minn.1986) (quotation omitted).
- State v. Gates 615 N.W.2d 331 Minn. 2000
- State v. Gates 615 N.W.2d 331 Minn. 2000