materiality standard in Minnesota

9 Minnesota opinions name it 2 courts 1982–2024 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 (17)

Case	Followed	Cited
Heitman v. Cronstroms Manufacturing, Inc.green minnctapp · 1987 · cited in 2 Minnesota opinions naming this issue, 2016–2016 2 sentences 2016See Heitman v. Cronstroms Mfg., Inc., 401 N.W.2d 425, 427 (Minn. App. 1987); see also Hansen, 412 N.W.2d at 323 . 2016See Heitman v. Cronstroms Mfg., Inc., 401 N.W.2d 425, 427 (Minn. App. 1987); see also Hansen, 412 N.W.2d at 323 .	2	2
In Re Claim of Tilsethgreen minn · 1973 · cited in 2 Minnesota opinions naming this issue, 2016–2016 2 sentences 2016The materiality standard has its origins in Tilseth v. Midwest Lumber Co., 295 Minn. 372, 374-75 , 204 N.W.2d 644, 646 (Minn. 1973), a case we decided before the Legislature adopted a statutory definition of “employment misconduct.” Act of Apr. 23, 1997, ch. 66, § 49, 1997 Minn. Laws 357 , 387.7 (Minn. 1997) (declining to address issues not raised below); see also Travelers Indem. 2016The materiality standard has its origins in Tilseth v. Midwest Lumber Co., 295 Minn. 372, 374-75 , 204 N.W.2d 644, 646 (Minn. 1973), a case we decided before the Legislature adopted a statutory definition of “employment misconduct.” Act of Apr. 23, 1997, ch. 66, § 49, 1997 Minn. Laws 357 , 387.7 (Minn. 1997) (declining to address issues not raised below); see also Travelers Indem.	2	2
Independent School District No. 709 v. Hansengreen minnctapp · 1987 · cited in 2 Minnesota opinions naming this issue, 2016–2016 2 sentences 2016See Heitman v. Cronstroms Mfg., Inc., 401 N.W.2d 425, 427 (Minn. App. 1987); see also Hansen, 412 N.W.2d at 323 . 2016See Heitman v. Cronstroms Mfg., Inc., 401 N.W.2d 425, 427 (Minn. App. 1987); see also Hansen, 412 N.W.2d at 323 .	2	2
Race v. Stategreen minn · 1993 · cited in 2 Minnesota opinions naming this issue, 2013–2015 2 sentences 2015Race v. State, 504 N.W.2d 214, 217-18 (Minn.1993). 2013We have held that for evidence to meet the materiality requirement it “must be credible.” Race v. State, 504 N.W.2d 214, 217-18 (Minn.1993).	2	2
Rainer v. Stategreen minn · 1997 · cited in 1 Minnesota opinions naming this issue, 2015–2015 2 sentences 2015Following an evidentiary hearing, the postconviction court determined that, because the witnesses who testified on Bobo’s behalf were not credible, the evidence that Bobo presented as newly discovered failed to satisfy the materiality requirement of the test announced in Rainer v. State, 566 N.W.2d 692, 695 (Minn.1997). 2015After considering the witnesses’ demeanor and the substance of their testimony, the post-conviction court found that, because D.T. and J.L. were not credible, Bobo failed to satisfy the materiality requirement of the newly discovered evidence test set forth in Rainer, 566 N.W.2d at 695 . 2 Having determined that Bobo failed to satisfy the Rainer test, the postconviction court explained that Bobo had necessarily failed to satisfy the more stringent statutory standard for newly discovered evidence set forth in Minn.Stat. § 590.01, subd. 4(b)(2) (2014).	1	1
State v. Hurdgreen minn · 2009 · cited in 1 Minnesota opinions naming this issue, 2010–2010 1 sentence 2010Gorman v. State, 619 N.W.2d 802, 805-06 (Minn.App.2000), rev. denied (Feb. 21, 2001); compare Hunt, 615 N.W.2d at 299 (quoting Bagley, 473 U.S. at 682 , 105 S.Ct. 3375 ) (requiring that a defendant show a reasonable probability that *218 the outcome at trial would have been different had the undisclosed evidence been produced), with Hurd, 763 N.W.2d at 34 (requiring that the defendant demonstrate that the evidence would probably have produced a more favorable outcome at trial).	1	1
Gorman v. Stategreen minnctapp · 2000 · cited in 1 Minnesota opinions naming this issue, 2010–2010 1 sentence 2010Gorman v. State, 619 N.W.2d 802, 805-06 (Minn.App.2000), rev. denied (Feb. 21, 2001); compare Hunt, 615 N.W.2d at 299 (quoting Bagley, 473 U.S. at 682 , 105 S.Ct. 3375 ) (requiring that a defendant show a reasonable probability that *218 the outcome at trial would have been different had the undisclosed evidence been produced), with Hurd, 763 N.W.2d at 34 (requiring that the defendant demonstrate that the evidence would probably have produced a more favorable outcome at trial).	1	1
State v. Huntgreen minn · 2000 · cited in 1 Minnesota opinions naming this issue, 2010–2010 1 sentence 2010Gorman v. State, 619 N.W.2d 802, 805-06 (Minn.App.2000), rev. denied (Feb. 21, 2001); compare Hunt, 615 N.W.2d at 299 (quoting Bagley, 473 U.S. at 682 , 105 S.Ct. 3375 ) (requiring that a defendant show a reasonable probability that *218 the outcome at trial would have been different had the undisclosed evidence been produced), with Hurd, 763 N.W.2d at 34 (requiring that the defendant demonstrate that the evidence would probably have produced a more favorable outcome at trial).	1	1
United States v. Bagleygreen scotus · 1985 · cited in 1 Minnesota opinions naming this issue, 2010–2010 2 sentences 2010Gorman v. State, 619 N.W.2d 802, 805-06 (Minn.App.2000), rev. denied (Feb. 21, 2001); compare Hunt, 615 N.W.2d at 299 (quoting Bagley, 473 U.S. at 682 , 105 S.Ct. 3375 ) (requiring that a defendant show a reasonable probability that 218 the outcome at trial would have been different had the undisclosed evidence been produced), with Hurd, 763 N.W.2d at 34 (requiring that the defendant demonstrate that the evidence would probably have produced a more favorable outcome at trial). 2010Gorman v. State, 619 N.W.2d 802, 805-06 (Minn.App.2000), rev. denied (Feb. 21, 2001); compare Hunt, 615 N.W.2d at 299 (quoting Bagley, 473 U.S. at 682 , 105 S.Ct. 3375 ) (requiring that a defendant show a reasonable probability that 218 the outcome at trial would have been different had the undisclosed evidence been produced), with Hurd, 763 N.W.2d at 34 (requiring that the defendant demonstrate that the evidence would probably have produced a more favorable outcome at trial).	1	1
State Ex Rel. Powderly v. Ericksongreen minn · 1979 · cited in 1 Minnesota opinions naming this issue, 1997–1997 2 sentences 1997See, e.g., Archabal, 495 N.W.2d at 421-22; Urban Council on Mobility v. Minnesota Dep’t of Natural Resources, 289 N.W.2d 729, 734 (Minn.1980); State by Powderly v. Erickson, 285 N.W.2d 84, 87-88 (Minn.1979); PEER, 266 N.W.2d at 867-68 . 1997See, e.g., Archabal, 495 N.W.2d at 421-22; Urban Council on Mobility v. Minnesota Dep't of Natural Resources, 289 N.W.2d 729, 734 (Minn.1980); State by Powderly v. Erickson, 285 N.W.2d 84, 87-88 (Minn.1979); PEER, 266 N.W.2d at 867-68 .	1	1
Urban Council on Mobility v. Minnesota Department of Natural Resourcesgreen minn · 1980 · cited in 1 Minnesota opinions naming this issue, 1997–1997 2 sentences 1997See, e.g., Archabal, 495 N.W.2d at 421-22; Urban Council on Mobility v. Minnesota Dep’t of Natural Resources, 289 N.W.2d 729, 734 (Minn.1980); State by Powderly v. Erickson, 285 N.W.2d 84, 87-88 (Minn.1979); PEER, 266 N.W.2d at 867-68 . 1997See, e.g., Archabal, 495 N.W.2d at 421-22; Urban Council on Mobility v. Minnesota Dep't of Natural Resources, 289 N.W.2d 729, 734 (Minn.1980); State by Powderly v. Erickson, 285 N.W.2d 84, 87-88 (Minn.1979); PEER, 266 N.W.2d at 867-68 .	1	1
Martin v. United Statesgreen ca5 · 1927 · cited in 1 Minnesota opinions naming this issue, 1982–1982 1 sentence 1982See State v. Borst, 278 Minn. 388, 397 , 154 N.W.2d 888, 894 (1967). [10] We cited a version of the Larrison rule in Whelan v. State, 298 Minn. 545 , 214 N.W.2d 344 (1972), in which we stated that a new trial should be granted in cases of recanted testimony "if (a) the defendant has acted with due diligence in seeking a new trial, and (b) the court is reasonably convinced that the witness has indeed recanted and that without this witness' perjured testimony at trial the jury might well have reached a different verdict." Id. at 545 , 214 N.W.2d at 344 ; see State v. Hill, 312 Minn. 514, 522 , 2	1	1
United States v. Consolidated Laundries Corporationgreen ca2 · 1961 · cited in 1 Minnesota opinions naming this issue, 1982–1982 1 sentence 1982Therefore, even though the Larrison rule contains a less stringent materiality standard, new trials nevertheless will not be granted unless the court can be reasonably certain that the recantation is genuine. [8] "Might" has been said to mean "something more than an outside chance although much less than the `would probably' of the Berry rule." Kyle v. United States, 297 F.2d 507, 512 (2d Cir. 1961). [9] We do not feel the need to reach the constitutional issue of whether this may amount to a denial of due process; instead, our decision is based on our conclusion that the denial of a new trial	1	1
Alastair Kyle v. United Statesgreen ca2 · 1961 · cited in 1 Minnesota opinions naming this issue, 1982–1982 2 sentences 1982“Might” has been said to mean “something more than an outside chance although much less than the ‘would probably’ of the Berry rule.” Kyle v. United States, 297 F.2d 507, 512 (2d Cir. 1961). . 1982Therefore, even though the Larrison rule contains a less stringent materiality standard, new trials nevertheless will not be granted unless the court can be reasonably certain that the recantation is genuine. [8] "Might" has been said to mean "something more than an outside chance although much less than the `would probably' of the Berry rule." Kyle v. United States, 297 F.2d 507, 512 (2d Cir. 1961). [9] We do not feel the need to reach the constitutional issue of whether this may amount to a denial of due process; instead, our decision is based on our conclusion that the denial of a new trial	1	1
State v. Borstgreen minn · 1967 · cited in 1 Minnesota opinions naming this issue, 1982–1982 2 sentences 1982See State v. Borst, 278 Minn. 388, 397 , 154 N.W.2d 888, 894 (1967). [10] We cited a version of the Larrison rule in Whelan v. State, 298 Minn. 545 , 214 N.W.2d 344 (1972), in which we stated that a new trial should be granted in cases of recanted testimony "if (a) the defendant has acted with due diligence in seeking a new trial, and (b) the court is reasonably convinced that the witness has indeed recanted and that without this witness' perjured testimony at trial the jury might well have reached a different verdict." Id. at 545 , 214 N.W.2d at 344 ; see State v. Hill, 312 Minn. 514, 522 , 2 1982See State v. Borst, 278 Minn. 388, 397 , 154 N.W.2d 888, 894 (1967). [10] We cited a version of the Larrison rule in Whelan v. State, 298 Minn. 545 , 214 N.W.2d 344 (1972), in which we stated that a new trial should be granted in cases of recanted testimony "if (a) the defendant has acted with due diligence in seeking a new trial, and (b) the court is reasonably convinced that the witness has indeed recanted and that without this witness' perjured testimony at trial the jury might well have reached a different verdict." Id. at 545 , 214 N.W.2d at 344 ; see State v. Hill, 312 Minn. 514, 522 , 2	1	1
Whelan v. Stategreen minn · 1974 · cited in 1 Minnesota opinions naming this issue, 1982–1982 2 sentences 1982See State v. Borst, 278 Minn. 388, 397 , 154 N.W.2d 888, 894 (1967). [10] We cited a version of the Larrison rule in Whelan v. State, 298 Minn. 545 , 214 N.W.2d 344 (1972), in which we stated that a new trial should be granted in cases of recanted testimony "if (a) the defendant has acted with due diligence in seeking a new trial, and (b) the court is reasonably convinced that the witness has indeed recanted and that without this witness' perjured testimony at trial the jury might well have reached a different verdict." Id. at 545 , 214 N.W.2d at 344 ; see State v. Hill, 312 Minn. 514, 522 , 2 1982See State v. Borst, 278 Minn. 388, 397 , 154 N.W.2d 888, 894 (1967). [10] We cited a version of the Larrison rule in Whelan v. State, 298 Minn. 545 , 214 N.W.2d 344 (1972), in which we stated that a new trial should be granted in cases of recanted testimony "if (a) the defendant has acted with due diligence in seeking a new trial, and (b) the court is reasonably convinced that the witness has indeed recanted and that without this witness' perjured testimony at trial the jury might well have reached a different verdict." Id. at 545 , 214 N.W.2d at 344 ; see State v. Hill, 312 Minn. 514, 522 , 2	1	1
State v. Hillgreen minn · 1977 · cited in 1 Minnesota opinions naming this issue, 1982–1982 2 sentences 1982See State v. Borst, 278 Minn. 388, 397 , 154 N.W.2d 888, 894 (1967). [10] We cited a version of the Larrison rule in Whelan v. State, 298 Minn. 545 , 214 N.W.2d 344 (1972), in which we stated that a new trial should be granted in cases of recanted testimony "if (a) the defendant has acted with due diligence in seeking a new trial, and (b) the court is reasonably convinced that the witness has indeed recanted and that without this witness' perjured testimony at trial the jury might well have reached a different verdict." Id. at 545 , 214 N.W.2d at 344 ; see State v. Hill, 312 Minn. 514, 522 , 2 1982See State v. Borst, 278 Minn. 388, 397 , 154 N.W.2d 888, 894 (1967). [10] We cited a version of the Larrison rule in Whelan v. State, 298 Minn. 545 , 214 N.W.2d 344 (1972), in which we stated that a new trial should be granted in cases of recanted testimony "if (a) the defendant has acted with due diligence in seeking a new trial, and (b) the court is reasonably convinced that the witness has indeed recanted and that without this witness' perjured testimony at trial the jury might well have reached a different verdict." Id. at 545 , 214 N.W.2d at 344 ; see State v. Hill, 312 Minn. 514, 522 , 2	1	1

Distinguished, questioned or overruled (0)

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

Also cited on this issue (6)

Case	Cited	Years
Tilseth v. Midwest Lumber Co. green minn · 1973 2 sentences 2016The materiality standard has its origins in Tilseth v. Midwest Lumber Co., 295 Minn. 372, 374-75 , 204 N.W.2d 644, 646 (Minn. 1973), a case we decided before the Legislature adopted a statutory definition of “employment misconduct.” Act of Apr. 23, 1997, ch. 66, § 49, 1997 Minn. Laws 357 , 387.7 (Minn. 1997) (declining to address issues not raised below); see also Travelers Indem. 2016The materiality standard has its origins in Tilseth v. Midwest Lumber Co., 295 Minn. 372, 374-75 , 204 N.W.2d 644, 646 (Minn. 1973), a case we decided before the Legislature adopted a statutory definition of “employment misconduct.” Act of Apr. 23, 1997, ch. 66, § 49, 1997 Minn. Laws 357 , 387.7 (Minn. 1997) (declining to address issues not raised below); see also Travelers Indem.	2	2016–2016
Travelers Indemnity Co. v. Bloomington Steel & Supply Co. green minn · 2006 2 sentences 2016Co. v. Bloomington Steel & Supply Co., 718 N.W.2d 888 , 898 n.7 (Minn. 2006) (declining to reach issues raised in the amicus curiae brief because they were not decided by the lower courts). 2016Co. v. Bloomington Steel & Supply Co., 718 N.W.2d 888 , 898 n.7 (Minn. 2006) (declining to reach issues raised in the amicus curiae brief because they were not decided by the lower courts).	2	2016–2016
Walen v. State green minn · 2010 1 sentence 2024Because the materiality analysis “involves a mixed issue of fact and law, we review a district court’s materiality determination de novo.” Walen, 777 N.W.2d at 216 .	1	2024–2024
People for Environmental Enlightenment & Responsibility (PEER), Inc. v. Minnesota Environmental Quality Council green minn · 1978 2 sentences 1997See, e.g., Archabal, 495 N.W.2d at 421-22; Urban Council on Mobility v. Minnesota Dep’t of Natural Resources, 289 N.W.2d 729, 734 (Minn.1980); State by Powderly v. Erickson, 285 N.W.2d 84, 87-88 (Minn.1979); PEER, 266 N.W.2d at 867-68 . 1997See, e.g., Archabal, 495 N.W.2d at 421-22; Urban Council on Mobility v. Minnesota Dep't of Natural Resources, 289 N.W.2d 729, 734 (Minn.1980); State by Powderly v. Erickson, 285 N.W.2d 84, 87-88 (Minn.1979); PEER, 266 N.W.2d at 867-68 .	1	1997–1997
Pennsylvania v. Ritchie green scotus · 1987 2 sentences 1990It then cited Brady and Agurs , conducted a materiality analysis, and remanded for an in-camera inspection of the questioned evidence to determine whether it contained information that “probably would have changed the outcome of his trial.” Ritchie, 480 U.S. at 57-58 , 107 S.Ct. at 1001-02 . 1990It then cited Brady and Agurs , conducted a materiality analysis, and remanded for an in-camera inspection of the questioned evidence to determine whether it contained information that “probably would have changed the outcome of his trial.” Ritchie, 480 U.S. at 57-58 , 107 S.Ct. at 1001-02 .	1	1990–1990
United States v. Valenzuela-Bernal green scotus · 1982 2 sentences 1990Since we cannot say either that access to the documents would produce a “reasonable doubt” about the conviction or that appellant’s discovery request does not constitute a “fishing expedition,” we cannot conclude that discovery of documents relating to days when no theft is alleged to have taken place would “probably have changed the outcome of the trial.” See United States v. ValenzuelaBernal, 458 U.S. 858, 868 , 102 S.Ct. 3440, 3447 , 73 L.Ed.2d 1193 (1982). 1990Since we cannot say either that access to the documents would produce a “reasonable doubt” about the conviction or that appellant’s discovery request does not constitute a “fishing expedition,” we cannot conclude that discovery of documents relating to days when no theft is alleged to have taken place would “probably have changed the outcome of the trial.” See United States v. ValenzuelaBernal, 458 U.S. 858, 868 , 102 S.Ct. 3440, 3447 , 73 L.Ed.2d 1193 (1982).	1	1990–1990

Statutes the citing opinions construe

MN § Minn. Stat. § 645.16 (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 168 (1975–2026) CA 102 (1899–2026) DE 66 (1985–2026) IL 40 (1934–2026) PA 39 (1980–2026) MD 38 (1982–2025) VA 36 (1987–2026) NJ 28 (1963–2025) WA 25 (1983–2024) MI 22 (1971–2026) NY 22 (1851–2026) LA 20 (1982–2025) FL 19 (1985–2019) CO 18 (1983–2025) DC 17 (2001–2025) TN 17 (2000–2025) OH 17 (1987–2026) MO 17 (1986–2024) ID 14 (1985–2022) NC 14 (2006–2023) WI 13 (1978–2023) CT 11 (1960–2024) MN 9 (1982–2024) UT 8 (1991–2025) MS 8 (1987–2013) IN 8 (1988–2016) KS 8 (1961–2024) MA 8 (1985–2020) OR 8 (1985–2024) NV 6 (1994–2016) GA 6 (2021–2026) AL 5 (1989–2015) IA 5 (2011–2026) MT 5 (1998–2016) KY 5 (1982–2025) NE 4 (1998–2025) SC 4 (2004–2018) AZ 4 (1985–2018) SD 4 (2020–2025) HI 3 (2000–2023) ND 3 (1981–2016) WV 3 (1998–2018) WY 3 (1992–2025) RI 3 (1975–1998) VT 2 (1987–2001) NM 2 (1994–2025) ME 2 (2008–2013) OK 2 (2015–2015)

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.

← Caselaw search · G Cite Topics · Brief Check