Spreigl evidence similarity

Substantial similarity

A jury found defendant guilty of five offenses, including third degree murder and second degree manslaughter, based on evidence that he caused a woman’s death by injecting a mixture of heroin and methamphetamine into her arm.  On appeal, defendant raised multiple issues, including that the trial court erred by admitting evidence that defendant previously had injected other person with drugs as Spreigl evidence.  He noted that the charged offense occurred in his residence in 2016, but the Spreigl incidents occurred at unspecified locations in 1994 and other unspecified times.  The Minnesota Court of Appeals held that, in light of the conflicting evidence as to whether defendant injected the drugs into the victim’s arm, the State’s Spreigl evidence was relevant.  However, the trial court erred by convicting defendant of four offense sthat were lesser included of third degree murder.  Affirmed in part, reversed in part, and remanded.

State v. Lynch, A18-0456, Ramsey County.

Minnesota Criminal Defense Lawyer Lynne Torgerson was not attorney of record in this case.

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