State of Minnesota v. Christopher Paul Hilton, A16-0580

Hilton was charged with felony domestic assault (August incident) and first-degree burglary (September incident) after two encounters with his then-girlfriend C.S.; police observed the September break-in and arrested Hilton.
The August incident involved alleged choking and other physical assault; the September incident involved Hilton entering through a window and brandishing a liquor bottle.
The State sought to admit redacted transcripts of Hilton’s prior guilty pleas to three domestic-conduct-related offenses (2009 misdemeanor, 2012 fifth-degree assault, 2012 felony domestic assault) under Minn. Stat. § 634.20 as relationship evidence.
The district court admitted the transcripts over defense objection and gave modified CRIMJIG cautionary instructions (omitting one phrase about showing nature/extent of the relationship); prosecutor argued the evidence provided context for how Hilton interacts with C.S.
A jury convicted Hilton of both charged offenses; he appealed, arguing the prior-plea transcripts were unfairly prejudicial and their probative value did not outweigh prejudice.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Hilton)	Held
Admissibility of prior guilty-plea transcripts as relationship evidence under Minn. Stat. § 634.20	The transcripts are probative to show how Hilton interacts with intimate partners and thus provide context for his relationship with C.S.	The prior pleas are remote or duplicative, risk improper propensity inference, and their prejudicial effect outweighs probative value.	The court held the transcripts were admissible; probative value outweighed danger of unfair prejudice.
Sufficiency of limiting instructions about relationship evidence	Instructions given (modified CRIMJIG 2.07/3.30) and prosecutor’s closing kept use limited to context/interaction.	Omission of the phrase about showing nature/extent of the relationship made instructions insufficient to prevent misuse.	The court found the instructions adequate in context and that omission did not require reversal.

State v. Lindsey, 755 N.W.2d 752 (Minn. App. 2008) (standard: review admission of relationship evidence for abuse of discretion)
State v. Meyer, 749 N.W.2d 844 (Minn. App. 2008) (relationship evidence probative value assessed against prejudicial effect and state’s need)
State v. Matthews, 779 N.W.2d 543 (Minn. 2010) (relationship evidence illuminates history of relationship and can affect credibility)
State v. Bell, 719 N.W.2d 635 (Minn. 2006) (definition of unfair prejudice as persuasion by illegitimate means)
State v. Word, 755 N.W.2d 776 (Minn. App. 2008) (section 634.20 allows broader latitude than Rule 404(b); prosecutor’s argument examined for improper use)
Spreigl v. State, 272 Minn. 488 (Minn. 1965) (establishes limits on use of other-crimes evidence)