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643 N.W.2d 281

State v. Stewart

Supreme Court of Minnesota

Decided May 9, 2002

Supreme Court of Minnesota · decided 2002-05-09

Cited by 15 later decisions — most recently January 2019

15 state decisions

Key passage — most relied on by later courts

“Minn. R. Evid. 704. Stewart does not dispute that Dr. Swenson is a qualified medical expert whose testimony about abusive head trauma was helpful to the jury. 4 But he argues the district court abused its discretion by admitting her testimony that B.G.D.'s injuries were caused by abusive head trauma because (1) the state failed to demonstrate in response to his pretrial motion that the opinion had”

quoted by 1 later decision, including State v. Stewart

Good law ✅— No negative treatment on recordhow we know

Decided 2002-05-09

View the full empirical analysis of this case →

LANCASTER, Justice

¶1(concurring specially).

¶2I concur with the result. I write separately, however, because I disagree with the majority’s conclusion that the district court abused its discretion in admitting Spreigl evidence of appellant’s agreement to kill Tanya Achenbach’s husband. Under Minn. R. Evid. 404(b), evidence of “another crime, wrong, or act” may be admitted to show absence of mistake or accident. The majority holds that the district court abused its discretion by admitting the Spreigl evidence because the state failed to establish an overt act in furtherance of the conspiracy. In my view, the agreement itself, even if not accompanied by an overt act, was a “wrong” admissible under rule 404(b). As stated by the majority, the state established by clear and convincing evidence that appellant and Daniel Angus agreed to commit murder. Furthermore, appellant claimed he shot Anthony Basta because of the interpersonal dynamics between him and his car-mates; they were pressuring him and making him feel rejected. That appellant and Angus, two members of this very group, had recently agreed to engage in criminal activity was relevant and probative on the matter of the interpersonal dynamics and the effect of those dynamics on appellant’s state of mind when he shot Basta. Thus, I would hold that the district court was within its discretion in admitting this evidence.

ANDERSON, Russell A., Justice

¶3(concurring specially).

¶4I join in the special concurrence of Justice Lancaster.

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