reasonable doubt standard in Minnesota

2011A properly objected-to instructional error regarding an element of an offense requires a new trial only “ ‘if it cannot be said beyond a reasonable doubt that the error had no significant impact on the verdict.’ ” State v. Valtierra, 718 N.W.2d 425, 432 (Minn.2006) (quoting State v. Olson, 482 N.W.2d 212, 216 (Minn.1992)).

2011An erroneous jury instruction merits a new trial if we cannot say “ ‘beyond a reasonable doubt that the error had no significant impact on the verdict.’ ” State v. Valtierra, 718 N.W.2d 425, 433 (Minn.2006) (quoting State v. Olson, 482 N.W.2d 212, 216 (Minn.1992)).

2024“A properly objected-to instructional error regarding an element of an offense requires a new trial only if it cannot be said beyond a reasonable doubt that the error had no significant impact on the verdict.” State v. Koppi, 798 N.W.2d 358, 364 (Minn. 2011) (citation omitted) (internal quotation marks omitted).

2024“A properly objected-to instructional error regarding an element of an offense requires a new trial only if it cannot be said beyond a reasonable doubt that the error had 5 no significant impact on the verdict.” State v. Koppi, 798 N.W.2d 358, 364 (Minn. 2011) (quotations omitted).

2008“The party challenging a statute has the burden of demonstrating beyond a reasonable doubt a violation of some provision of the Minnesota Constitution.” In re Haggerty, 448 N.W.2d 363, 364 (Minn.1989).

2006Further, “[t]he party challenging a statute has the burden of demonstrating beyond a reasonable doubt a violation of some provision of the Minnesota Constitution.” In re Haggerty, 448 N.W.2d 363, 364 (Minn.1989); see also Miller Brewing Co. v. State, 284 N.W.2d 353, 356 (Minn.1979) (holding that person challenging constitutionality of a statute must “demonstrate[ ] beyond a reasonable doubt that the statute violates some constitutional provision”).

2024In Theis, the supreme court stated that when establishing a factual basis for an Alford plea, “[t]he best practice . . . is to have the defendant specifically acknowledge on the record . . . that the evidence the [s]tate would likely offer against him is sufficient for a jury, applying a reasonable doubt standard,” to find him guilty. 742 N.W.2d at 649 .

2017The district court should “have the defendant specifically acknowledge on the record at the plea hearing that the evidence the [s]tate would likely offer against him is sufficient for a jury, applying a reasonable doubt standard, to find the defendant guilty.” Theis, 742 N.W.2d at 649 ; see also Williams, 760 N.W.2d at 12-13 (noting that Theis relied on Norgaard precedent to clarify the Alford/Goulette accuracy standard).

2008“However, a finding of constitutional error in a criminal trial does not require a new trial if the state can show beyond a reasonable doubt that the error was harmless.” State v. Jones, 556 N.W.2d 903, 910 (Minn.1996).

2006Error in admission of tainted pretrial identification “does not require a new trial if the state can show beyond a reasonable doubt that the error was harmless.” State v. Jones, 556 N.W.2d 903, 913 (Minn.1996).

2024Failure to instruct the jury on a defendant’s defense when the evidence warrants it requires a new trial unless it can be said, “beyond a reasonable doubt that the error had no significant impact on the verdict.” State v. Pendleton, 567 N.W.2d 265, 270 (Minn. 1997).

2017“An error in jury instructions is not harmless and a new trial should be granted if it cannot be said beyond a reasonable doubt that the error had no significant impact on the verdict.” State v. Pendleton, 567 N.W.2d 265, 270 (Minn. 1997).

2014An erroneous jury instruction merits a new trial when it cannot be determined “beyond a reasonable doubt that the error had no significant impact on the verdict.” State v. Valtierra, 718 N.W.2d 425, 433 (Minn.2006) (quotation omitted).

2011A properly objected-to instructional error regarding an element of an offense requires a new trial only “ ‘if it cannot be said beyond a reasonable doubt that the error had no significant impact on the verdict.’ ” State v. Valtierra, 718 N.W.2d 425, 432 (Minn.2006) (quoting State v. Olson, 482 N.W.2d 212, 216 (Minn.1992)).

2009State v. Scott, 501 N.W.2d 608, 619 (Minn.1993).

1999Following these cases, we too have stated that "a finding of constitutional error in a criminal trial does not require a new trial if the state can show beyond a reasonable doubt that the error was harmless.” Jones, 556 N.W.2d at 910 (emphasis added); see also State v. Scott, 501 N.W.2d 608, 619 (Minn.1993) (citing Chapman, 386 U.S. at 24 , 87 S.Ct. 824 ).

2016See In re Winship, 397 U.S. 358, 363 , 90 S. Ct. 1068 , 15 1072 (1970) (stating that the presumption of innocence is “that bedrock ‘axiomatic and elementary’ principle whose ‘enforcement lies at the foundation of the administration of our criminal law,’” and the reasonable doubt standard of proof “provides concrete substance” for the presumption of innocence).

2016See In re Winship, 397 U.S. 358, 363 , 90 S. Ct. 1068 , 15 1072 (1970) (stating that the presumption of innocence is “that bedrock ‘axiomatic and elementary’ principle whose ‘enforcement lies at the foundation of the administration of our criminal law,’” and the reasonable doubt standard of proof “provides concrete substance” for the presumption of innocence).

2006Compare State v. Caron, 300 Minn. 123, 127-28 , 218 N.W.2d 197, 200 (1974) (using two-tiered standard), with State v. Swanson, 707 N.W.2d 645, 658 (Minn.2006) (applying harmless beyond a reasonable doubt standard).

2006Compare State v. Caron, 300 Minn. 123, 127-28 , 218 N.W.2d 197, 200 (1974) (using two-tiered standard), with State v. Swanson, 707 N.W.2d 645, 658 (Minn.2006) (applying harmless beyond a reasonable doubt standard).

2026See id. (stating that a trial jury’s finding of guilt under the reasonable-doubt standard supports a grand jury’s finding under the lower standard of probable cause).

2026See id. (stating that a trial jury’s finding of guilt under the reasonable-doubt standard supports a grand jury’s finding under the lower standard of probable cause).

2024A defendant is entitled to a new trial due to an erroneous jury instruction if “it cannot be said beyond a reasonable doubt that the error had no significant impact on the verdict.” Glowacki, 630 N.W.2d at 402 (citation omitted) (internal quotation marks omitted).

2023A defendant is entitled to a new trial due to an erroneous jury instruction “if it cannot be said beyond a reasonable doubt that the error had no significant impact on the verdict.” State v. Glowacki, 630 N.W.2d 392, 402 (Minn. 2001) (quotation omitted).

2024See State v. Keaton, 589 N.W.2d 85, 91 (Minn. 1998) (declining to determine whether an error standing alone would warrant a new trial because the “errors, taken cumulatively, deprived the appellant of his right to a fair trial”); see also Zumberge, 888 N.W.2d at 694 (harmless beyond a reasonable doubt standard); Tscheu, 758 N.W.2d at 863 (impact on substantial rights standard).

2010“Minnesota’s traditional circumstantial evidence standard incorporates the burden of proof in sufficiency review....” State v. Tscheu, 758 N.W.2d 849, 869 (Minn.2008) (Meyer, J., concurring).

2006Further, “[t]he party challenging a statute has the burden of demonstrating beyond a reasonable doubt a violation of some provision of the Minnesota Constitution.” In re Haggerty, 448 N.W.2d 363, 364 (Minn.1989); see also Miller Brewing Co. v. State, 284 N.W.2d 353, 356 (Minn.1979) (holding that person challenging constitutionality of a statute must “demonstrate[ ] beyond a reasonable doubt that the statute violates some constitutional provision”).

2003“The party challenging a statute has the burden of demonstrating beyond a reasonable doubt a violation of some provision of the Minnesota Constitution.” Haggerty, 448 N.W.2d at 364 (citation omitted); see also Miller Brewing Co. v. State, 284 N.W.2d 353, 356 (Minn.1979) (recognizing that a person challenging the constitutionality of a statute must overcome every presumption in favor of constitutionality).

1992McGuire v. C & L Restaurant, Inc., 346 N.W.2d 605, 611 (Minn.1984).

1989McGuire v. C & L Restaurant, Inc., 346 N.W.2d 605, 611 (Minn.1984).

1986See Hauwiller v. State, 295 N.W.2d 641, 643 (Minn.1980).

1984Hauwiller v. State., 295 N.W.2d 641, 643 (Minn.1980). 1.

2006The Court "requir[ed] the beneficiary of a constitutional error to prove beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained." Id.

2006The Court “requir[ed] the beneficiary of a constitutional error to prove beyond a reasonable doubt that the error complained of did not contribute to the verdict obtained.” Id.

2026We will grant a new trial if an appellant can establish that the jury instructions were erroneous and “if it cannot be said beyond a reasonable doubt that the error had no significant impact on the verdict.” State v. Kuhnau, 622 N.W.2d 552, 558-59 (Minn. 2001). “[A] person may act in self-defense if he or she reasonably believes that force is necessary and uses only the level of force reasonably necessary to prevent the bodily harm feared.” State v. Devens, 852 N.W.2d 255, 258 (Minn. 2014).

2025“An error in jury instructions is not harmless and a new trial should be granted if it cannot be said beyond a reasonable doubt that the error had no significant impact on the verdict.” State v. Chauvin, 989 N.W.2d 1 , 28 (Minn. App. 2023) (quoting State v. Kuhnau, 622 N.W.2d 552 , 558–59 (Minn. 2001)), rev. denied (Minn. July 18, 2023).

2024The 9 supreme court in Theis specifically stated that the factual basis for the Alford plea in State v. Ecker, 524 N.W.2d 712 (Minn. 1994) was sufficient, based in part on defense counsel asking “Ecker if he would agree ‘that if a jury were to hear all of that evidence and put it together, they would undoubtedly come to the conclusion that’” he was guilty of shooting the victim.

2016A defendant entering an Alford plea or a Norgaard plea must “agree[] that evidence the State is likely to offer at trial is sufficient to convict” and should “specifically acknowledge on the record at the plea hearing that the evidence the State would likely offer against him is sufficient for a jury, applying a reasonable doubt standard, to find the defendant guilty.” Theis, 742 N.W.2d at 649 ; Ecker, 524 N.W.2d at 716-17 .

2006Compare State v. Caron, 300 Minn. 123, 127-28 , 218 N.W.2d 197, 200 (1974) (using two-tiered standard), with State v. Swanson, 707 N.W.2d 645, 658 (Minn.2006) (applying harmless beyond a reasonable doubt standard).

2006Compare State v. Caron, 300 Minn. 123, 127-28 , 218 N.W.2d 197, 200 (1974) (using two-tiered standard), with State v. Swanson, 707 N.W.2d 645, 658 (Minn.2006) (applying harmless beyond a reasonable doubt standard).

2007See State v. Juarez, 572 N.W.2d 286, 291 (Minn.1997).

2007See State v. Juarez, 572 N.W.2d 286, 291 (Minn.1997).

2004“It is critical that the moral force of the criminal law not be diluted by a standard of proof that leaves people in doubt whether innocent men are being *487 condemned.” Winship, 397 U.S. at 364 , 90 S.Ct. 1068 ; see also State v. Tibbetts, 281 N.W.2d 499, 500 (Minn.1979) (ordering a new trial when the jury instructions obscured and diluted the reasonable doubt standard).

2003Tibbetts, 281 N.W.2d at 500 .

1992In dissent to McMillan , Justice Stevens stated that, “[bjecause the Pennsylvania statute challenged in this case describes conduct that the Pennsylvania Legislature obviously intended to prohibit, and because it mandates lengthy incarceration for the same, I believe the conduct so described is an element of the criminal offense to which the proof beyond a reasonable doubt requirement applies.” Id., ill U.S. at 96, 106 S.Ct. at 2421 (Stevens, J., dissenting).

1992In dissent to McMillan , Justice Stevens stated that, “[bjecause the Pennsylvania statute challenged in this case describes conduct that the Pennsylvania Legislature obviously intended to prohibit, and because it mandates lengthy incarceration for the same, I believe the conduct so described is an element of the criminal offense to which the proof beyond a reasonable doubt requirement applies.” Id., ill U.S. at 96, 106 S.Ct. at 2421 (Stevens, J., dissenting).

2026See State v. Jackson, 773 N.W.2d 111 , 122–23 (Minn. 2009) (concluding the prosecutor gave “a legitimate explanation of the State’s burden”).

2026We will grant a new trial if an appellant can establish that the jury instructions were erroneous and “if it cannot be said beyond a reasonable doubt that the error had no significant impact on the verdict.” State v. Kuhnau, 622 N.W.2d 552, 558-59 (Minn. 2001). “[A] person may act in self-defense if he or she reasonably believes that force is necessary and uses only the level of force reasonably necessary to prevent the bodily harm feared.” State v. Devens, 852 N.W.2d 255, 258 (Minn. 2014).

2025The Supreme Court’s analysis in Smith supports a conclusion that venue is not an element of an offense because, if it were, retrial would necessarily be barred under the Burks and Clark decisions concerning when the Double Jeopardy Clause applies. 7 In State v. Johnson, we recognized that in previous cases we had assumed without deciding that the reasonable doubt standard applies. 995 N.W.2d 155 , 161 n.4 (Minn. 2023) (citing State v. Carignan, 272 N.W.2d 748, 749 (Minn. 1978) (concluding that evidence was sufficient to establish venue); State v. Heidelberg, 12 N.W.2d 781, 782 (Minn. 1944) (co