"Evidence of threats to witnesses may be relevant in showing consciousness of guilt." Holt v. State, 772 N.W.2d 470, 481 (Minn. 2009) (quotation omitted). But "this inference is inappropriate when the threats cannot be traced directly to the defendant."

Id. Similarly, in State v. Holt, 772 N.W.2d 470 (Minn. 2009) cert. denied, 130 S. Ct. 2073 (2010), the supreme court held that the district court did not err by failing to strike a juror who was the victim of an attempted burglary during the trial. Id. at 476-78.

Id. We disagreed, holding that “Rule 26.02 provides the exclusive grounds to challenge for implied bias,” and that the relationship between the juror and the company was not one covered by Rule 26.02.Id. at 318; see also Williams, 764 N.W.2d at 28 (declining to extend implied bias to a juror who may have lied about another juror's racist remarks);Holt v. State, 772 N.W.2d 470, 477 (Minn.2009) (declining to extend the doctrine of implied bias where a juror's home was burgled, but there was no connection between the defendant and the attempted burglary, and the case involved a different type of crime). Subdivision 5 sets outs 11 grounds on which one may challenge a juror for cause. Knowledge of a prior conviction is not one of the 11, unless it constitutes actual bias: that the juror's state of mind “satisfies the court that the juror cannot try the case impartially and without prejudice to the substantial rights of the challenging party.”

We review a district court's decision to admit evidence for an abuse of discretion. Holt v. State, 772 N.W.2d 470, 481 (Minn.2009). We defer to the court's evidentiary rulings because the court stands “in the best position to evaluate the prejudicial nature” of evidence.

Permitting a biased juror to serve is structural error requiring automatic reversal because the error “undermines the basic structural integrity of the criminal tribunal itself.” Holt v. State, 772 N.W.2d 470, 477 (Minn.2009) (citation omitted) (internal quotation marks omitted). In analyzing whether the district court erred by seating a juror, the relevant inquiry is whether the juror had a biased state of mind, in reference to either the case or a party, so as to demonstrate that she “cannot try the case impartially and without prejudice to the substantial rights of the challenging party.”

"In determining whether a defendant's Faretta rights have been respected, the primary focus must be on whether the defendant had a fair chance to present his case in his own way." Holt v. State, 772 N.W.2d 470, 479 (Minn. 2009) (quotation omitted). Such "[q]uestions of constitutional law are reviewed de novo."

"A defendant claiming error in the district court's reception of evidence has the burden of showing both the error and the prejudice resulting from the error." Holt v. State, 772 N.W.2d 470, 483 (Minn. 2009) (quotation omitted). If the district court erred in admitting evidence, "the reviewing court determines whether there is a reasonable possibility that the wrongfully admitted evidence significantly affected the verdict."

"A defendant claiming error in the district court's reception of evidence has the burden of showing both the error and the prejudice resulting from the error." Holt v. State, 772 N.W.2d 470, 483 (Minn. 2009)

"A determination that a statement meets the foundational requirements of a hearsay exception is reviewed for an abuse of discretion." Holt v. State, 772 N.W.2d 470, 483 (Minn. 2009). The "residual exception" to the hearsay rule is outlined in Rule 807; specifically, the rule states:

"A determination that a statement meets the foundational requirements of a hearsay exception is reviewed for an abuse of discretion." Holt v. State, 772 N.W.2d 470, 483 (Minn. 2009). "But whether the admission of evidence violates a criminal defendant's rights under the Confrontation Clause is a question of law this court reviews de novo."