MN Court of Appeals Issues Key Ruling on Hearsay Evidence in Criminal Trials
A recent decision from the Minnesota Court of Appeals could have lasting implications for how certain types of hearsay evidence are admitted in criminal trials across the state. In State v. Jenkins, the court ruled that the district court erred in admitting a forensic interview of a child, referred to as E.J., and that the interview did not qualify under either the “prior consistent statement” exception or the “medical treatment” exception to the hearsay rule. This case centers on a fundamental principle of criminal law: a defendant has the right to confront and challenge the evidence against them. Hearsay—statements made outside of court offered to prove the truth of what they assert—is typically inadmissible unless it falls under specific, narrowly defined exceptions.
In Jenkins, the trial court allowed a forensic interview of E.J. into evidence without clearly explaining the legal basis for its decision. The state later claimed it was admissible as a prior consistent statement or under the medical-treatment exception. However, the Court of Appeals disagreed, finding that the trial court had abused its discretion.
According to the appellate court, it was unclear whether the district court admitted the interview as a prior consistent statement or under the medical-treatment exception. At pretrial, the district court informed the parties that it intended to accept the interview, but it did not state the grounds for admission. The Court of Appeals found that this discrepancy was not a harmless error, and there is a reasonable possibility that this mistake could have significantly impacted the jury’s decision.
Why Does This Matter for Future Minnesota Defendants?
First, the ruling reinforces the importance of procedural rigor in admitting evidence. The district court admitted the interview without watching it and without evaluating whether it truly met the criteria for an exception to hearsay. The Court of Appeals highlighted this as problematic, signaling to lower courts that they must make clear, supportable findings before admitting such evidence. Second, the decision clarifies the application of the prior consistent statement exception. A statement can only be admitted on that basis if it is actually consistent with in-court testimony. In this case, the defense argued—credibly—that E.J.’s trial testimony conflicted with the earlier interview, undermining its admissibility.
Finally, the case draws a sharp line on the medical treatment exception. Not all forensic interviews—even those occurring alongside medical evaluations- qualify. The courts must look closely at whether the purpose of the interview was truly medical or primarily investigative.
For criminal defense attorneys and defendants alike, State v. Jenkins serves as a strong reminder that hearsay rules are not mere formalities; they are constitutional safeguards that uphold the integrity of the Court system. This ruling strengthens the right to a fair trial and ensures that all evidence admitted in court meets high legal standards.
North Star Criminal Defense Can Help
When existing laws are modified or new laws are introduced that change the landscape of the Criminal Justice System, it can be tough to navigate. At North Star Criminal Defense, our experienced criminal defense attorneys stay up to date on the ever-changing system and possess the skillset to effectively address new laws and regulations, providing the best defense for our clients.