We view the evidence in the light most favorable to the verdict when determining whether the jury acted with due regard for the presumption of innocence and for the need to overcome it by proof beyond a reasonable doubt. State v. Steinbuch, 514 N.W.2d 793, 799 (Minn. 1994). Furthermore, a conviction based on circumstantial evidence will be upheld and such evidence is entitled to as much weight as any other kind of evidence, so long as a detailed review of the record indicates that the reasonable inferences from such evidence are consistent only with the defendant's guilt and inconsistent with any rational hypothesis except that of guilt.
A defendant who claims the trial court erred in admitting evidence bears the burden of showing the error and any resulting prejudice. See State v. Steinbuch, 514 N.W.2d 793, 799 (Minn. 1994). As a general rule, evidence of other crimes or misconduct is not admissible to prove the defendant's character for the purpose of showing that he or she acted in conformity with that character.
An alternative theory does not justify a new trial if that theory is not plausible or supported by the evidence. See State v. Wallace, 558 N.W.2d 469, 473 (Minn. 1997); State v. Steinbuch, 524 N.W.2d 793, 800 (Minn. 1994). Appellant does not point to any evidence in the record that might support his alternative scenario.
On appeal, the defendant has the burden of proving both that the trial court abused its discretion in admitting the evidence and that the defendant was thereby prejudiced. State v. Steinbuch, 514 N.W.2d 793, 799 (Minn. 1994) (citation omitted). Reversal is warranted only when the error substantially influences the jury's decision.
Intent may be proved by circumstantial evidence including the defendant's conduct, State v. Whisonant, 331 N.W.2d 766, 768 (Minn. 1983), and the character of the assault, State v. Steinbuch, 514 N.W.2d 793, 800 (Minn. 1994). Further, intent may be inferred from events occurring before and after the crime.
Admission of Spreigl evidence lies within the sound discretion of the trial court, and a trial court's ruling will not be reversed absent a clear abuse of discretion. State v. Steinbuch, 514 N.W.2d 793, 800 (Minn. 1994). In August of 1984, Spaeth was arrested for two burglaries, one of an occupied dwelling in Lakeville, and one of an occupied dwelling in Apple Valley. He later admitted that he also had committed a burglary that took place on June 27, 1984, in Apple Valley.
State v. Bauer, 598 N.W.2d 352, 367 (Minn. 1999) (quoting State v. Blanchard, 315 N.W.2d 427, 432 (Minn. 1982)); see also State v. Steinbuch, 514 N.W.2d 793, 797 (Minn. 1994) (concluding that statements that homicide victim was going to take her girls and leave was relevant to rebut defendant's claim that the victim, his wife, murdered his daughter and step-daughter). Nevertheless, the state-of-mind exception "does not pave the way for statements by one person to prove another's state of mind."
We assume that the jury believed the state's witnesses and disbelieved any evidence to the contrary. State v. Steinbuch, 514 N.W.2d 793, 799 (Minn. 1994); State v. Moore, 438 N.W.2d 101, 108 (Minn. 1989).
A defendant who claims the trial court erred in admitting evidence bears the burden of showing the error and any resulting prejudice. See State v. Steinbuch, 514 N.W.2d 793, 799 (Minn. 1994). Pursuant to Minn. R. Evid. 404(b), a defendant may seek to introduce evidence of other crimes or misconduct of a third person to prove "motive, opportunity, intent, preparation, plan, knowledge, identity, or absence of mistake or accident."
A defendant appealing the admission of evidence has the burden to show the admission was both erroneous and prejudicial. Id. (citing State v. Steinbuch, 514 N.W.2d 793, 799 (Minn. 1994)). Minnesota has long adhered to the common-law rule excluding evidence of prior bad acts except where the evidence fits within a specific exception.