Dolo v. State
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The Supreme Court reversed the decision of the court of appeals reversing Defendant's request for postconviction relief and remanding the case for a new trial, holding that the trial court did not abuse its discretion under Minn. R. Evid. 106 by overruling Defendant's objection and allowing the jury to hear only an excerpt of a recorded police interview.
Defendant was charged with second-degree sexual conduct. At trial, the State offered as evidence an eight-minute excerpt of an hour-long, videotaped, voluntary interview of Defendant by a police detective. Defendant objected and argued that the entire recording should be admitted into evidence and played for the jury under Rule 106. The trial court overruled the objection and played only the requested excerpt for the jury. The jury found Defendant guilty. Defendant filed a petition for postconviction relief, challenging the trial court's decision to play only the excerpt of the police interview for the jury. The district court denied postconviction relief. The court of appeals reversed, concluding that the entire interview should have been played for the jury. The Supreme Court reversed, holding that the trial court did not abuse its discretion when it properly overruled Defendant's objection under Rule 106.
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