Spreigl analysis in Minnesota

2008Evid. 404(b), otherwise known as the Spreigl rule, states that “[e]vidence of another crime, wrong, or act is not admissible to prove the character of a person in order to show action in conformity therewith.” See also State v. Spreigl, 272 Minn. 488 , 139 N.W.2d 167 (1965).

2008Evid. 404(b), otherwise known as the Spreigl rule, states that “[e]vidence of another crime, wrong, or act is not admissible to prove the character of a person in order to show action in conformity therewith.” See also State v. Spreigl, 272 Minn. 488 , 139 N.W.2d 167 (1965).

2015We examine the whole record and determine “whether there is a reasonable possibility that the wrongfully admitted evidence significantly affected the verdict.” Bolte, 530 N.W.2d at 198 (quotation omitted).

2005See, e.g., State v. Moorman, 505 N.W.2d 593, 602 (Minn.1993); State v. DeWald, 464 N.W.2d 500, 504 (Minn.1991); see also State v. Bolte, 530 N.W.2d 191, 197 (Minn.1995).

2008Cf. State v. Kennedy, 585 N.W.2d 385, 390 (Minn.1998) (holding that, for the purpose of a Spreigl analysis, “evidence of other crimes, including subsequent ones, may be admitted for a proper purpose”).

2008Cf. State v. Kennedy, 585 N.W.2d 385, 390 (Minn.1998) (holding that, for the purpose of a Spreigl analysis, “evidence of other crimes, including subsequent ones, may be admitted for a proper purpose”).

2015Because the purpose of an appeal regarding both joinder and Spreigl issues is to determine whether the introduction of evidence of other crimes was prejudicial, a Spreigl analysis “serves as a useful framework for evaluating the possible prejudicial effect of improperly joining offenses.” Profit, 591 N.W.2d at 461 .

2015Because the purpose of an appeal regarding both joinder and Spreigl issues is to determine whether the introduction of evidence of other crimes was prejudicial, a Spreigl analysis “serves as a useful framework for evaluating the possible prejudicial effect of improperly joining offenses.” Profit, 591 N.W.2d at 461 .

2016Cf. State v. Kasper, 409 N.W.2d 846, 847 (Minn. 1987) (faulting court of appeals and holding that trial court at Spreigl hearing had broad discretion to decide whether or not to require state to call Spreigl witnesses or instead to rely on prosecutor’s offer of proof).

2016The dissent begins and ends its disagreement with our holding as to the clear and convincing quality of the state’s Spreigl-hearing evidence by relying on State v. Kasper, 409 N.W.2d at 847 , for the proposition that “[t]he state overstated the strength of its evidence connecting Davis to the Lake Calhoun shooting at the Spreigl hearing.” The dissent accurately quotes the Kasper court as stating that “the trial court and the appellate 7 courts are always free to grant relief, when appropriate, if the evidence adduced was not what the prosecutor led the trial court to expect.” (Emphasis added.)

2024Prior bad act evidence satisfies the fourth requirement of the Spreigl exception “when there is a sufficiently close relationship between the charged offense and the Spreigl offense in terms of time, place, or modus operandi.” State v. Gomez, 721 N.W.2d 871, 878 (Minn. 2006).

2024Prior bad act evidence satisfies the fourth requirement of the Spreigl exception “when there is a sufficiently close relationship between the charged offense and the Spreigl offense in terms of time, place, or modus operandi.” State v. Gomez, 721 N.W.2d 871, 878 (Minn. 2006).

2016See Hollins, 765 N.W.2d at 131–32 (noting that a Spreigl analysis is unnecessary if the evidence of another crime is intrinsic to the crime charged).

2016See Hollins, 765 N.W.2d at 131–32 (noting that a Spreigl analysis is unnecessary if the evidence of another crime is intrinsic to the crime charged).

2011See State v. Bauer, 598 N.W.2d 352, 364 (Minn.1999) (applying Spreigl analysis to relationship evidence by requiring the district court to find by clear and convincing evidence that defendant committed the prior act and that the probative value of the evidence outweighs any unfair prejudice). 1.

2000See State v. Bauer, 598 N.W.2d 352, 364 (Minn.1999) (holding that before admitting “relationship” evidence, court must find it to be shown by clear and convincing evidence and to have probative value outweighing potential for unfair prejudice); State v. Williams, 593 N.W.2d 227, 236 (Minn.1999) (same).

2002Profit, 591 N.W.2d at 460-61 (stating that analysis for Spreigl evidence is useful framework for evaluating possible prejudicial effect of improperly joining unrelated offenses); State v. Kates, 610 N.W.2d 629, 631 (Minn.2000) (rejecting harmless error analysis for review of improper joinder of unrelated offenses, citing Profit , as holding that Spreigl analysis is proper framework for evaluating whether such joinder is so prejudicial that reversal is necessary).

2000But the supreme court then went on to state that, as articulated in State v. Profit, 591 N.W.2d 451 (Minn.1999), the Spreigl analysis is the correct framework for evaluating “whether an erroneous failure to sever is so prejudicial that reversal is necessary.” Kates, 610 N.W.2d at 631 (citation omitted).

2024In addition, under the Spreigl exception, evidence of prior bad acts may be admitted for limited purposes, including to show “motive, intent, knowledge, identity, absence of mistake or accident, or a common scheme or plan.” Ness, 707 N.W.2d at 685 .

2024In addition, under the Spreigl exception, evidence of prior bad acts may be admitted for limited purposes, including to show “motive, intent, knowledge, identity, absence of mistake or accident, or a common scheme or plan.” Ness, 707 N.W.2d at 685 .

2016See Ross, 732 N.W.2d at 280 .

2015In its Spreigl analysis to determine whether the improper joinder was prejudicial, the supreme court stated that a “jury’s determination that a defendant is not guilty of a particular crime does not preclude a subsequent determination that, at the time of the trial, the defendant’s participation in underlying conduct related to the acquitted offense was supported by clear and convincing evidence.” Id. at 281 . 7 Following this approach, we consider whether, at the time of trial, there was clear- and-convincing evidence that Banks sexually assaulted M.Y.

1987In both Casady and this case the court of appeals seems to interpret our decision in State v. Doughman, 384 N.W.2d 450 (Minn.1986), as requiring the state to call the Spreigl victim at the Spreigl hearing and have the trial court weigh the credibility of the victim in any case where the only evidence that the offense occurred is the victim herself.

1987In both Casady and this case the court of appeals seems to interpret our decision in State v. Doughman, 384 N.W.2d 450 (Minn.1986), as requiring the state to call the Spreigl victim at the Spreigl hearing and have the trial court weigh the credibility of the victim in any case where the only evidence that the offense occurred is the victim herself.

2024State v. Riddley, 776 N.W.2d 419, 424 (Minn. 2009) (concerning evidence admitted under the immediate episode exception); State v. Smith (Smith II), 940 N.W.2d 497 , 503 (Minn. 2020)13 (concerning evidence admitted under the Spreigl exception).

2024State v. Riddley, 776 N.W.2d 419, 424 (Minn. 2009) (concerning evidence admitted under the immediate episode exception); State v. Smith (Smith II), 940 N.W.2d 497 , 503 (Minn. 2020)13 (concerning evidence admitted under the Spreigl exception).

2016State v. Brown, 739 N.W.2d 716, 720 (Minn. 2007) (“Inquiry on cross- examination into common gang membership may be sufficiently probative to show bias . . . .”).

2016In addition, the state’s production of one uncertain eyewitness and hearsay statements at trial to establish that Davis aided and abetted the attempted murder of K.W. at Lake Calhoun in 2010 did not conform to its offer of proof and was “simply too incomplete.” State v. Link, 289 N.W.2d 102, 106 (Minn. 1979) (quotation omitted).

2016In addition, the state’s production of one uncertain eyewitness and hearsay statements at trial to establish that Davis aided and abetted the attempted murder of K.W. at Lake Calhoun in 2010 did not conform to its offer of proof and was “simply too incomplete.” State v. Link, 289 N.W.2d 102, 106 (Minn. 1979) (quotation omitted).

2016The third problem with admitting the relationship evidence in this case is even more compelling – the state did not need evidence of appellant’s conduct involving R.E. to provide context for his relationship with N.E. “[W]hen considering admissibility, the district court is not required to independently consider the state’s need for such evidence as ‘the need for section 634.20 evidence is naturally considered as part of the assessment of the probative value versus prejudicial effect of the evidence.’” State v. Word, 755 N.W.2d 776, 784 (Minn. App. 2008) (quoting State v. Bell, 719 N.W.2d 635,

2016The third problem with admitting the relationship evidence in this case is even more compelling – the state did not need evidence of appellant’s conduct involving R.E. to provide context for his relationship with N.E. “[W]hen considering admissibility, the district court is not required to independently consider the state’s need for such evidence as ‘the need for section 634.20 evidence is naturally considered as part of the assessment of the probative value versus prejudicial effect of the evidence.’” State v. Word, 755 N.W.2d 776, 784 (Minn. App. 2008) (quoting State v. Bell, 719 N.W.2d 635,

2015“Even if an error at trial, standing alone, would not be sufficient to require reversal, the cumulative effect of the errors may compel reversal.” State v. Houston, 654 N.W.2d 727, 737 (Minn. App. 2003), review denied (Minn. Mar. 26, 2003).

2015“Even if an error at trial, standing alone, would not be sufficient to require reversal, the cumulative effect of the errors may compel reversal.” State v. Houston, 654 N.W.2d 727, 737 (Minn. App. 2003), review denied (Minn. Mar. 26, 2003).

2014State v. Heath, 685 N.W.2d 48, 59 (Minn. App. 2004) (quotation omitted), review denied (Minn. Nov. 16, 2004).

2009See McCoy, 682 N.W.2d at 161 (stating that unique treatment of evidence under section 634.20 is “appropriate in the context of ... domestic abuse”). *561 Under our interpretation, if the defendant is charged both with burglary and a domestic-abuse crime, the state can utilize section 634.20.

2009See McCoy, 682 N.W.2d at 161 (stating that unique treatment of evidence under section 634.20 is “appropriate in the context of ... domestic abuse”). *561 Under our interpretation, if the defendant is charged both with burglary and a domestic-abuse crime, the state can utilize section 634.20.

2007See, e.g., State v. Profit, 591 N.W.2d 451, 460-61 (Minn.1999); State v. Conaway, 319 N.W.2d 35, 42 (Minn.1982).

2007See, e.g., State v. Profit, 591 N.W.2d 451, 460-61 (Minn.1999); State v. Conaway, 319 N.W.2d 35, 42 (Minn.1982).

2005See, e.g., State v. Moorman, 505 N.W.2d 593, 602 (Minn.1993); State v. DeWald, 464 N.W.2d 500, 504 (Minn.1991); see also State v. Bolte, 530 N.W.2d 191, 197 (Minn.1995).

2005See, e.g., State v. Moorman, 505 N.W.2d 593, 602 (Minn.1993); State v. DeWald, 464 N.W.2d 500, 504 (Minn.1991); see also State v. Bolte, 530 N.W.2d 191, 197 (Minn.1995).

2005See, e.g., State v. Moorman, 505 N.W.2d 593, 602 (Minn.1993); State v. DeWald, 464 N.W.2d 500, 504 (Minn.1991); see also State v. Bolte, 530 N.W.2d 191, 197 (Minn.1995).

2005See, e.g., State v. Moorman, 505 N.W.2d 593, 602 (Minn.1993); State v. DeWald, 464 N.W.2d 500, 504 (Minn.1991); see also State v. Bolte, 530 N.W.2d 191, 197 (Minn.1995).

2002State v. Kates, 616 N.W.2d 296, 300 (Minn.App.2000), review denied (Minn. Oct. 25, 2000).

2002State v. Kates, 616 N.W.2d 296, 300 (Minn.App.2000), review denied (Minn. Oct. 25, 2000).

2001The record is not clear as to whether the trial court admitted the Lake County over-the-clothes evidence as other-crimes Spreigl evidence or as "relationship evidence.” See generally State v. Salas, 306 N.W.2d 832, 836 (Minn.1981) (noting that where evidence bears directly on the history of the relationship between the defendant and the victim, the state is not required to follow the Spreigl rule as a condition of getting the evidence admitted).

2001The record is not clear as to whether the trial court admitted the Lake County over-the-clothes evidence as other-crimes Spreigl evidence or as "relationship evidence.” See generally State v. Salas, 306 N.W.2d 832, 836 (Minn.1981) (noting that where evidence bears directly on the history of the relationship between the defendant and the victim, the state is not required to follow the Spreigl rule as a condition of getting the evidence admitted).

2000See State v. Bauer, 598 N.W.2d 352, 364 (Minn.1999) (holding that before admitting “relationship” evidence, court must find it to be shown by clear and convincing evidence and to have probative value outweighing potential for unfair prejudice); State v. Williams, 593 N.W.2d 227, 236 (Minn.1999) (same).

2000See State v. Bauer, 598 N.W.2d 352, 364 (Minn.1999) (holding that before admitting “relationship” evidence, court must find it to be shown by clear and convincing evidence and to have probative value outweighing potential for unfair prejudice); State v. Williams, 593 N.W.2d 227, 236 (Minn.1999) (same).