What Is Relationship Evidence in Minnesota Domestic Assault Cases?

Imagine being charged for one alleged incident, only to learn that the prosecutor intends to present the jury with allegations of conduct from months or years before. In Minnesota domestic assault cases, this can happen through relationship evidence. Because this type of evidence might reveal allegations beyond the specific charge, it can be especially harmful and a significant concern for the defense.

What Is Relationship Evidence?

According to Minnesota Statute § 634.20, evidence of specific domestic conduct by the accused toward the alleged victim or other household members can be admitted in court. This includes domestic abuse, violations of protection orders, stalking, harassment, violations of restraining orders, and certain domestic-abuse no-contact order breaches.

Minnesota courts recognize that understanding a single alleged incident can be difficult without context. Therefore, relationship evidence may be used to clarify the parties’ history and to provide context for the charged offense. This is not necessarily limited to previous conduct with the same alleged victim; under certain circumstances, conduct involving a different family or household member may also be relevant. 

When Is Relationship Evidence Admissible?

Relationship evidence is not automatically allowed in court. According to § 634.20, this evidence may be introduced if its probative value outweighs the risks of unfair prejudice, confusion, or misleading the jury. Essentially, the evidence needs to offer relevant context without encouraging the jury to use it improperly.

Relationship evidence isn’t meant to prove that someone has a bad character and likely committed the offense. However, in practice, it’s just a way for the State to get in bad character evidence about the defendant in hopes of getting a conviction at all costs – justice be damned. Because, for a jury, if the defendant did it before, he/she must have done it now. 

Recent Court Case

A recent Minnesota Court of Appeals ruling in State v. Donson underscores just how far this relationship evidence can go. The defendant was convicted of threatening violence toward D.M., the boyfriend of his former partner, A.L.

During the trial, A.L. (essentially a witness) was allowed to offer limited testimony regarding the defendant’s past behavior toward her. The defendant argued that the victim was neither a family nor household member, so his conduct toward A.L. was not relevant regarding his relationship with the former boyfriend, D.M. He also correctly (at least in our humble opinion) argued that the testimony risked becoming improper character or propensity evidence. The State countered, stating that A.L.’s testimony helped clarify the relationships among Donson, A.L., and D.M.

Amazingly, the Court of Appeals did not even determine if the evidence was properly admitted under § 634.20. Instead, it held that any error was harmless. The court noted that A.L.’s testimony was limited, the prosecutor referred to it only once during the closing argument, the jury received two cautionary instructions, and the State had video and audio evidence of the threat. So, in sum, even though the “relationship” evidence was not about the relationship at issue and did not involve an actual relationship, the State still tried to and succeeded in getting bad character evidence into evidence as “relationship” evidence. And the Court of Appeals essentially said, who cares?!?! He was doomed regardless. Asinine, yes, but it goes to show how this type of evidence can be abused by the State because, even when they’re wrong in getting it in, the courts still find ways to overlook it. Justice, or something.

Why Does Relationship Evidence Require a Strong Defense?

Relationship evidence can influence how jurors interpret the rest of the case, affecting perceptions of a defendant’s intent, witness credibility, and conflicting accounts. And once jurors hear a damaging allegation about prior conduct, no limited instruction can make the jury unhear what was said. A criminal defense attorney may pre-emptively challenge whether the prior conduct falls under § 634.20, if the required family or household relationship exists, whether the evidence offers relevant context, or if the risk of unfair prejudice outweighs its value. 

At North Star Criminal Defense, we understand how significantly relationship evidence can affect a domestic assault criminal case. If you or someone you know is facing domestic assault or another domestic-related charge in Minnesota, contact North Star Criminal Defense today for a confidential case review.