fourth and fifth factors (Minnesota) · Go Syfert
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fourth and fifth factors in Minnesota

9 Minnesota opinions name it 2 courts 1995–2024 1 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 (8)

CaseFollowedCited
State v. Swansongreen
minn · 2006 · cited in 3 Minnesota opinions naming this issue, 2014–2014
2 sentences

2014See Swanson, 707 N.W.2d at 655 (grouping the fourth and fifth factors together). “[I]f the defendant’s credibility is the central issue in the case . . . a greater case can be made for admitting the impeachment evidence, because the need for the evidence is greater.” State v. Bettin, 295 N.W.2d 542, 546 (Minn. 1980).

2014See Swanson, 707 N.W.2d at 655 (grouping the fourth and fifth factors together).

33
State v. Ihnotgreen
minn · 1998 · cited in 2 Minnesota opinions naming this issue, 2003–2014
2 sentences

2014See State v. Smith, 669 N.W.2d 19, 29 (Minn. 2003) (citing Ihnot, 575 N.W.2d at 587 ) (stating that the fourth and fifth factors of the Jones analysis are satisfied if the defendant’s credibility is a central issue in the case), overruled by State v. Leake, 699 N.W.2d 312 (Minn. 2005); State v. Gassler, 505 N.W.2d 62, 67 (Minn. 1993) (stating that the importance-of-defendant’s-testimony factor supports exclusion of impeachment evidence if, by admitting it, a defendant’s account of the events would not be heard by the jury). 9 Flowers also contends that, because his prior conviction and the pre

2003See State v. Ihnot, 575 N.W.2d 581, 587 (Minn.1998) (holding that fourth and fifth Jones factors were satisfied where the defendant's credibility would have been a central issue in the case).

12
State v. Gomezgreen
minn · 2006 · cited in 1 Minnesota opinions naming this issue, 2024–2024
1 sentence

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).

11
McDaniel v. Bieffe USA, Inc.green
mnd · 1999 · cited in 1 Minnesota opinions naming this issue, 2018–2018
2 sentences

2018Id.

2018See id.

11
State v. Gasslergreen
minn · 1993 · cited in 1 Minnesota opinions naming this issue, 2014–2014
1 sentence

2014See State v. Smith, 669 N.W.2d 19, 29 (Minn. 2003) (citing Ihnot, 575 N.W.2d at 587 ) (stating that the fourth and fifth factors of the Jones analysis are satisfied if the defendant’s credibility is a central issue in the case), overruled by State v. Leake, 699 N.W.2d 312 (Minn. 2005); State v. Gassler, 505 N.W.2d 62, 67 (Minn. 1993) (stating that the importance-of-defendant’s-testimony factor supports exclusion of impeachment evidence if, by admitting it, a defendant’s account of the events would not be heard by the jury). 9 Flowers also contends that, because his prior conviction and the pre

11
State v. Leakegreen
minn · 2005 · cited in 1 Minnesota opinions naming this issue, 2014–2014
1 sentence

2014See State v. Smith, 669 N.W.2d 19, 29 (Minn. 2003) (citing Ihnot, 575 N.W.2d at 587 ) (stating that the fourth and fifth factors of the Jones analysis are satisfied if the defendant’s credibility is a central issue in the case), overruled by State v. Leake, 699 N.W.2d 312 (Minn. 2005); State v. Gassler, 505 N.W.2d 62, 67 (Minn. 1993) (stating that the importance-of-defendant’s-testimony factor supports exclusion of impeachment evidence if, by admitting it, a defendant’s account of the events would not be heard by the jury). 9 Flowers also contends that, because his prior conviction and the pre

11
State v. Bettingreen
minn · 1980 · cited in 1 Minnesota opinions naming this issue, 2014–2014
2 sentences

2014Credibility is central to the case “if the issue for the jury narrows to a choice between defendant’s credibility and that of one other person.” Id. 7 The district court determined that these factors weighed in favor of admissibility because: “if [Renville] decides to testify and offers testimony that conflicts with the State’s witnesses, his credibility would certainly be central to his case.” Because Renville testified and his credibility was a central issue the district court correctly determined that this factor weighed in favor of admissibility.

2014See Swanson, 707 N.W.2d at 655 (grouping the fourth and fifth factors together). “[I]f the defendant’s credibility is the central issue in the case . . . a greater case can be made for admitting the impeachment evidence, because the need for the evidence is greater.” State v. Bettin, 295 N.W.2d 542, 546 (Minn. 1980).

11
State v. Smithgreen
minn · 2003 · cited in 1 Minnesota opinions naming this issue, 2014–2014
1 sentence

2014See State v. Smith, 669 N.W.2d 19, 29 (Minn. 2003) (citing Ihnot, 575 N.W.2d at 587 ) (stating that the fourth and fifth factors of the Jones analysis are satisfied if the defendant’s credibility is a central issue in the case), overruled by State v. Leake, 699 N.W.2d 312 (Minn. 2005); State v. Gassler, 505 N.W.2d 62, 67 (Minn. 1993) (stating that the importance-of-defendant’s-testimony factor supports exclusion of impeachment evidence if, by admitting it, a defendant’s account of the events would not be heard by the jury). 9 Flowers also contends that, because his prior conviction and the pre

11

Distinguished, questioned or overruled (1)

CaseNegativeCited
State v. Ihnotgreen
minn · 1998 · cited in 2 Minnesota opinions naming this issue, 2003–2014
2 sentences

2014See State v. Smith, 669 N.W.2d 19, 29 (Minn. 2003) (citing Ihnot, 575 N.W.2d at 587 ) (stating that the fourth and fifth factors of the Jones analysis are satisfied if the defendant’s credibility is a central issue in the case), overruled by State v. Leake, 699 N.W.2d 312 (Minn. 2005); State v. Gassler, 505 N.W.2d 62, 67 (Minn. 1993) (stating that the importance-of-defendant’s-testimony factor supports exclusion of impeachment evidence if, by admitting it, a defendant’s account of the events would not be heard by the jury). 9 Flowers also contends that, because his prior conviction and the pre

2003See State v. Ihnot, 575 N.W.2d 581, 587 (Minn.1998) (holding that fourth and fifth Jones factors were satisfied where the defendant's credibility would have been a central issue in the case).

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Also cited on this issue (2)

CaseCitedYears
Juelich v. Yamazaki Mazak Optonics Corp. green
minn · 2004
1 sentence

2014The supreme court stated that the fourth and fifth factors continue to be consistent with U.S. Supreme Court precedent because a majority of justices in Asahi agreed that the exercise of jurisdiction would be “unreasonable and unfair” after weighing “the burden on the defendant, the interests of the forum state, and the plaintiffs interest in obtaining relief.” Id. at 572-73 .

12014–2014
Hime v. State Farm Fire & Casualty Co. green
minn · 1979
2 sentences

1995Hime, 284 N.W.2d at 833 .

1995Hime, 284 N.W.2d at 833 .

11995–1995

Statutes the citing opinions construe

MN § Minn. Stat. § 480A.08 (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

TX 44 (2000–2025) MN 9 (1995–2024) IL 6 (2012–2026) CA 5 (2011–2015) OH 4 (1999–2018) WA 4 (1982–2019) MI 3 (2025–2025) OR 3 (2019–2026) VA 2 (2022–2023) MT 2 (2013–2013) PA 2 (2014–2023) MD 2 (1995–2010) TN 2 (2009–2020) AZ 2 (2007–2014)

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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