Cited by

Opinions in Minnesota that cite In Re the Welfare of K.A.S., 585 N.W.2d 71.

33 citing documents.

State of Minnesota v. Steven John Stolp-Thompson 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,”
State of Minnesota v. Sylvester Jones Minn. Ct. App. 2026
(holding that the admission of a videotaped statement that was “reasonably consistent” with trial testimony was not reversible error).
State of Minnesota v. Michael Jay Honan 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)).
State of Minnesota v. Jeremy Scott Jenkins 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
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).
State of Minnesota v. David Howard Kollars 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 v. Anthony Robinson Minn. Ct. App. 2023
State of Minnesota v. Jose Francisco Velasquez-Lazo Minn. Ct. App. 2021
State of Minnesota v. David Ronald Leonard Minn. Ct. App. 2020
State of Minnesota v. Patrick Lamar Newsom, Jr. Minn. Ct. App. 2020
State of Minnesota v. Earl Jay Murphy 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 v. Kenneth Raynold Sleen Minn. Ct. App. 2020
State of Minnesota v. Sandra Kay Kouba Minn. Ct. App. 2019
State of Minnesota v. Darrell Wayne Brownbull, Jr. Minn. Ct. App. 2019
State of Minnesota v. Hector Garcia Garcia Minn. Ct. App. 2019
State of Minnesota v. Bradly James Haddock Minn. Ct. App. 2019
( holding videotaped statement “reasonably consistent” with witness’s trial testimony admissible under Minn. R. Evid.
State of Minnesota v. Simon Benjamin Danquah Minn. Ct. App. 2019
State of Minnesota v. Rene Mercedes Rivas-Hernandez 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 v. Michael Darnell Hampton Minn. Ct. App. 2018
State of Minnesota v. Lance Arnold Kingbird Minn. Ct. App. 2018
State of Minnesota v. Michael Anthony Llona Minn. Ct. App. 2017
d 71, 75–76 (Minn. App. 1998).
State of Minnesota v. James Richard Jerome Cochran 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
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
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
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)).