pattern jury instruction (Minnesota) · Go Syfert
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pattern jury instruction in Minnesota

16 Minnesota opinions name it 2 courts 2002–2026 4 in the last five years

The cases below were cited by Minnesota courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (10)

CaseFollowedCited
State v. Goodloegreen
minn · 2006 · cited in 2 Minnesota opinions naming this issue, 2010–2016
2 sentences

2016State v. Goodloe, 718 N.W.2d 413, 422 (Minn.2006).

2010Id. at 422 .

12
State v. Broulikgreen
minn · 2000 · cited in 1 Minnesota opinions naming this issue, 2026–2026
2 sentences

2026See 10 Minnesota 15 Practice, CRIMJIG 2.03 (2023); see also State v. Broulik, 606 N.W.2d 64, 68-71 (Minn. 2000) (approving the pattern jury instruction on the limited purpose of Spreigl evidence). 5 As the district court did, we recognize the prejudicial nature of the Spreigl evidence against Gomez.

2026See 10 Minnesota 15 Practice, CRIMJIG 2.03 (2023); see also State v. Broulik, 606 N.W.2d 64, 68-71 (Minn. 2000) (approving the pattern jury instruction on the limited purpose of Spreigl evidence). 5 As the district court did, we recognize the prejudicial nature of the Spreigl evidence against Gomez.

11
State v. Ostremgreen
minn · 1995 · cited in 1 Minnesota opinions naming this issue, 2025–2025
2 sentences

2025See 10 Minnesota Practice, CRIMJIG 3.08 (2024) (providing similar reliability factors as in State v. Ostrem, 535 N.W.2d 916 (Minn. 1995)).

2025We note that the pattern jury instruction was not used at Lafore’s trial and that this is not challenged on appeal. 10 reliable.” Ostrem, 535 N.W.2d at 921 .

11
State v. Mitchellgreen
minn · 1998 · cited in 1 Minnesota opinions naming this issue, 2016–2016
1 sentence

2016“The refusal to give a requested jury instruction lies within the discretion of the district court and no error results if no abuse of discretion is shown.” State v. Mitchell, 577 N.W.2d 481, 493 (Minn.1998) (quotation omitted).- A district court does not abuse its discretion by using a pattern jury instruction when that instruction accurately states the law.

11
State v. Turnipseedgreen
minn · 1980 · cited in 1 Minnesota opinions naming this issue, 2015–2015
2 sentences

2015In State v. Gassler, the supreme court emphasized that it had explicitly approved the pattern jury instruction as an appropriate instruction on circumstantial evidence. 505 N.W.2d 62, 68 (Minn. 2007) (citing State v. Turnipseed, 297 N.W.2d 308, 312 (Minn. 1980)).

2015The court explained that while the rational-hypothesis test is appropriate for determining the sufficiency of the evidence on appeal, it “does not apply to jury instructions.” Id.

11
State v. Gasslergreen
minn · 1993 · cited in 1 Minnesota opinions naming this issue, 2015–2015
1 sentence

2015In State v. Gassler, the supreme court emphasized that it had explicitly approved the pattern jury instruction as an appropriate instruction on circumstantial evidence. 505 N.W.2d 62, 68 (Minn. 2007) (citing State v. Turnipseed, 297 N.W.2d 308, 312 (Minn. 1980)).

11
In Re Welfare of G. (NMN) M.green
minn · 1997 · cited in 1 Minnesota opinions naming this issue, 2015–2015
1 sentence

2015Here, the district court instructed the jury to determine whether the objective facts would “support an officer’s reasonable belie[f] that Mr. Mason was driving.” Probable cause, in addition to being defined as an “honest and strong suspicion,” has also at times been stated in terms of an officer’s “reasonable belief.” See, e.g., In re Welfare of G.M., 560 N.W.2d 687, 695 (Minn. 1997) (noting that probable cause requires police to have a “reasonable belief”).

11
State v. Clarkgreen
minn · 2008 · cited in 1 Minnesota opinions naming this issue, 2015–2015
1 sentence

2015See State v. Clark, 755 N.W.2d 241, 251 (Minn. 3 The pattern jury instruction provides in part: You cannot find the defendant guilty of a crime on the testimony of a person who could be charged with that crime, unless that testimony is corroborated by other evidence that tends to convict the defendant of the crime.

11
State v. Olmscheidgreen
minnctapp · 1992 · cited in 1 Minnesota opinions naming this issue, 2007–2007
1 sentence

2007In State v. Olmscheid, 492 N.W.2d 263, 265 (Minn.App.1992), we held that the criminal-refusal statute “incorporates to some degree the provisions of the implied consent statute into the crime of refusal.” 2 In Olmscheid , as here, the district court instructed the jury on refusal to test using the pattern jury instruction.

11
State v. Martingreen
minn · 1977 · cited in 1 Minnesota opinions naming this issue, 2006–2006
1 sentence

2006In State v. Martin, we upheld the pattern jury instruction on premeditation. 261 N.W.2d 341, 345 (Minn.1977).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Minnesota. Read the followed side critically anyway.

Also cited on this issue (8)

CaseCitedYears
Canada by and Through Landy v. McCarthy green
minn · 1997
2 sentences

2005The original commentary to CIVJIG 91.40 suggested that the instruction was derived from Canada by handy v. McCarthy, 567 N.W.2d 496 (Minn.1997).

2002The current pattern jury instruction on pre-existing conditions represents a significant departure from these rules in that it permits an allocation of liability to the defendant for a plaintiffs pre-existing condition if the jury is unable to determine what part of the plaintiffs injuries predated the accident. 4A Minnesota District Judges Association, Minnesota Practice, Jury Instruction Guides Civil, JIG 91.40 (4th ed.1999). 2 The commentary to CIVJIG 91.40 suggests its derivation from Canada by Bandy v. McCarthy, 567 N.W.2d 496 (Minn.1997).

22002–2005
State v. Lowe green
minn · 1896
1 sentence

2025Id. at 78 n.3 (observing that the erroneous language in the pattern jury instruction purportedly was taken from this court’s decision in State v. Lowe, 68 N.W. 1094 (Minn. 1896) (citing 10 Minn. Dist.

12025–2025
State v. Weltz green
minn · 1923
2 sentences

2024Thus, the supreme court determined that the pattern jury instruction given at Coleman’s trial “materially misstated the law.” Id.

2024The supreme court explained that the pattern instruction improperly “attaches the recklessness component to the act itself, and allows for conviction based on an impermissibly low risk of death.” Id.

12024–2024
State v. Meger green
minn · 2017
1 sentence

2024Heard argues that, even though the rule of law announced in Coleman adheres to precedent, it is a new rule of law because, before Coleman was decided, “[t]he consensus in the legal community—as expressed by the pattern jury instruction—was wrong.” 4 4 Heard relies on Meger, in which the supreme court held that State v. Her, 862 N.W.2d 692 (Minn. 2015), announced a new rule of law. 901 N.W.2d at 425 .

12024–2024
State of Minnesota v. Ge Her green
minn · 2015
1 sentence

2024Heard argues that, even though the rule of law announced in Coleman adheres to precedent, it is a new rule of law because, before Coleman was decided, “[t]he consensus in the legal community—as expressed by the pattern jury instruction—was wrong.” 4 4 Heard relies on Meger, in which the supreme court held that State v. Her, 862 N.W.2d 692 (Minn. 2015), announced a new rule of law. 901 N.W.2d at 425 .

12024–2024
State v. Lindsey green
minn · 2001
2 sentences

2016Id. at 662 ; see 10 Minnesota Practice, CRIMJIG 3.19 (1990).

2016As in Lindsey, the district court here instructed the jury using the pattern jury instruction, which has not changed from the version of which the supreme court approved in Lindsey. 11 Compare 10 Minnesota Practice, CRIMJIG 3.19 (2015), with 632 N.W.2d at 662 (quoting 10 Minnesota Practice, CRIMJIG 3.19 (1990).

12016–2016
State v. Smith green
minn · 2004
1 sentence

2016The third question presented by this case is whether the district court erred in its instruction, on reasonable doubt because it used language from State v. Smith, 674 N.W.2d 398 (Minn.2004), rather than th,e language of the pattern jury instruction.

12016–2016
Johnson v. State green
minnctapp · 1988
1 sentence

2002The language in the pattern jury instruction that provides that the state does not have to prove intentional infliction of great bodily harm is based on Johnson v. State, 421 N.W.2d 327 (Minn.App.1988).

12002–2002

Statutes the citing opinions construe

MN § Minn. Stat. § 480A.08 (5) MN § Minn. Stat. § 609.185 (3) MN § Minn. Stat. § 609.19 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

NC 108 (1982–2026) CA 84 (1996–2026) GA 78 (1975–2026) WA 63 (1980–2026) TN 56 (1992–2026) IL 53 (1978–2026) WI 44 (1982–2025) MD 40 (2000–2026) IN 39 (1992–2025) AL 35 (1990–2025) CO 28 (1984–2026) NY 24 (1973–2023) ND 17 (1979–2026) MN 16 (2002–2026) KS 9 (1995–2025) SD 8 (1975–2024) DE 7 (2012–2022) WY 7 (1981–2025) NE 7 (2008–2021) ID 6 (1990–2013) AK 5 (2021–2025) DC 4 (2004–2022) MT 4 (2004–2026) MS 3 (1998–2019) MO 3 (1993–2020) OH 2 (2008–2024) MA 2 (1993–2010)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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