Cited by
Opinions in Minnesota that cite In Re the Welfare of K.A.S., 585 N.W.2d 71.
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State of Minnesota, Respondent,
Minn. Ct. App. 2026
To be admissible under rule 801(d)(1)(B), a witness’s “trial testimony and the prior statement need not be verbatim,” Bakken, d at 109, so long as they are “reasonably consistent,”
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State of Minnesota, Respondent,
Minn. Ct. App. 2026
(holding that the admission of a videotaped statement that was “reasonably consistent” with trial testimony was not reversible error).
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State of Minnesota, Respondent,
Minn. Ct. App. 2026
See, (affirming decision to admit forensic interview of child sexual-abuse victim where the requirements of rule 801(d)(1)(B) were satisfied and any discrepancy between the victim’s trial testimony and interview “was not substantial”); (concluding that forensic interview of child sexual-abuse victim was not erroneously admitted under rule 801(d)(1)(B)).
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, A23-0930
Minn. Ct. App. 2025
To be admissible under rule 801(d)(1)(B), a witness’s “trial testimony and the prior statement need not be verbatim,” Bakken, d at 109, so long as they are “reasonably consistent.”
- State of Minnesota v. Curtis Dwayne Thurston Minn. Ct. App. 2023
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State of Minnesota v. Curtis Dwayne Thurston
Minn. Ct. App. 2023
(holding that a videotaped interview was admissible even though statements made therein were more detailed than the declarant-witness’s trial testimony).
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State of Minnesota, Respondent,
Minn. Ct. App. 2023
The trial testimony “need not be verbatim” or exact in every detail, id., as long as it is “reasonably consistent” with the prior statement
- State of Minnesota, Respondent, Minn. Ct. App. 2023
- State of Minnesota, Respondent, Minn. Ct. App. 2021
- State of Minnesota, Respondent, Minn. Ct. App. 2020
- State of Minnesota, Respondent, Minn. Ct. App. 2020
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State of Minnesota, Respondent,
Minn. Ct. App. 2020
and admission of a videotaped stateme nt that is ‘reasonably consistent’ with the trial testimony is not reversible error.” ().
- State of Minnesota, Respondent, Minn. Ct. App. 2020
- State of Minnesota, Respondent, Minn. Ct. App. 2019
- State of Minnesota, Respondent, Minn. Ct. App. 2019
- State of Minnesota, Respondent, Minn. Ct. App. 2019
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State of Minnesota, Respondent,
Minn. Ct. App. 2019
( holding videotaped statement “reasonably consistent” with witness’s trial testimony admissible under Minn. R. Evid.
- State of Minnesota, Respondent, Minn. Ct. App. 2019
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State of Minnesota, Respondent,
Minn. Ct. App. 2019
24, 2000); (videotaped statement that was “reasonably consistent” with witness’s trial testimony admissible under Rule 801(d)(1)(B)).
- State of Minnesota, Respondent, Minn. Ct. App. 2018
- State of Minnesota, Respondent, Minn. Ct. App. 2018
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State of Minnesota, Respondent,
Minn. Ct. App. 2017
d 71, 75–76 (Minn. App. 1998).
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State of Minnesota, Respondent,
Minn. Ct. App. 2017
Prior to admission “‘the witness’[s] credibility must have been challenged, and the statement must bolster the witness’[s] credibility with respect to that aspect of the witness’[s] credibility that was challenged.’” ().
- State of Minnesota v. Miguel Angel Martinez-Duran Minn. Ct. App. 2015
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State of Minnesota v. Miguel Angel Martinez-Duran
Minn. Ct. App. 2015
(stating that the admission of reasonable consistent statements does not constitute reversible error).
- State of Minnesota v. Tyrone Joseph Mohr Minn. Ct. App. 2014
- State of Minnesota v. Tyrone Joseph Mohr Minn. Ct. App. 2014
- State v. Zulu 706 N.W.2d 919 Minn. Ct. App. 2005
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State v. Zulu
706 N.W.2d 919
Minn. Ct. App. 2005
The trial testimony and the prior statement need not be identical to be consistent, id., and admission of a videotaped statement that is “reasonably consistent” with the trial testimony is not reversible error
- In Re the Welfare of B.J.M. 636 N.W.2d 155 Minn. Ct. App. 2001
- In Re the Welfare of B.J.M. 636 N.W.2d 155 Minn. Ct. App. 2001
- State v. Bakken 604 N.W.2d 106 Minn. Ct. App. 2000
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State v. Bakken
604 N.W.2d 106
Minn. Ct. App. 2000
Apr.13, 1999) (“minor discrepancies” did not prevent videotaped statement from being consistent with trial testimony); (videotaped statement that was “reasonably consistent” with witness’s trial testimony admissible under Rule 801(d)(1)(B)).