The Minnesota Court of Appeals Monday, July 15, upheld Crow Wing County District Court’s decision regarding a 37-year-old Brainerd man convicted of domestic assault last year.
Kyle Delane Johnson challenged his conviction of domestic assault, arguing the district court abused its discretion by admitting relationship evidence. The Court of Appeals affirmed the Brainerd district court’s decision to allow the evidence at Johnson’s trial.
The decision was considered and decided by Presiding Judge Jill Flaskamp Halbrooks and judges Randall J. Slieter and Roger Klaphake.
Johnson was arrested April 17, 2018, by Brainerd police after he assaulted a woman. He was convicted of felony domestic assault and fifth-degree drug possession.
During the trial, the Crow Wing County Attorney’s Office wanted to introduce relationship evidence, including the recordings of nine jail communications between Johnson and the victim, with whom he had a relationship. The district court ruled the recordings were admissible as relationship evidence.
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Johnson was sentenced to concurrent terms of 30 months for domestic assault and 21 months for fifth-degree possession of a controlled substance.
According to the unpublished appeals court opinion, Johnson argued the district court erred by admitting evidence of the jail communications between himself and the victim as they were not “domestic conduct” as defined by the statute. He asserted the prosecution sought admission only under the statute and did not base it on case law. Johnson’s argument was relationship evidence admitted under state law has a broader category of relationship evidence than is admissible under case law.
The court of appeals stated the district court admitted the relationship evidence under state law and case law, which showed evidence of a strained relationship and also assisted in accessing the witness’ credibility.
The district court found the jail communications reflected Johnson’s behavior as “antagonistic, hostile, aggressive, threatening, demeaning, which would be within the heart of relationship evidence,” the court document stated. During the recordings, Johnson was aggressive, controlling and he consistently berated the victim, showing a strained relationship.
Johnson also stated the district court abused its discretion by admitting the relationship evidence because the potential for unfair prejudice outweighed its probative value.
“As discussed, the relationship evidence had substantial probative value. And we are not persuaded by Johnson’s argument that the evidence was unfairly prejudicial because it reflected poorly on him ‘as a person and a romantic partner’ and ‘invited the fact-finder to draw a propensity inference that … Johnson was likely guilty because he was generally a bad boyfriend.’ The purpose of relationship evidence is to show a strained relationship between the defendant and victim, and therefore the mere fact that it reflects poorly on the defendant is not a basis to exclude it. And we note that Johnson was tried by the district court, rather than a jury, which further reduces the chance that the evidence was used for an improper purpose.”
The court of appeals again ruled in favor of the district court on this argument.
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