State of Minnesota v. Frank James Bigbear, 10 N.W.3d 48

Frank James Bigbear was convicted for third-degree criminal sexual conduct after allegedly sexually assaulting I.M., a 14-year-old, when Bigbear was in his early thirties.
At trial, the State introduced both live testimony and a recorded video interview of I.M. conducted shortly after the alleged assault.
Bigbear objected to the admission of the recorded interview on hearsay grounds, but the court admitted it; other recorded interviews with eyewitnesses (Mother and Boyfriend) were admitted without objection.
The court of appeals found error in admitting the recorded interview, as it did not meet applicable hearsay exceptions, but nevertheless held the error was harmless and affirmed the conviction.
The Supreme Court of Minnesota granted review to determine whether the harmless-error analysis was conducted under the correct standard and, if not, whether the error was nonetheless harmless under the proper standard.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Correct standard for harmless-error review	Bigbear argued the court of appeals used the wrong standard by focusing only on whether remaining evidence was sufficient for conviction.	State contended the verdict would have been the same based on the rest of the evidence.	The court of appeals applied the wrong standard; harmless-error review asks if the wrongly admitted evidence could have significantly influenced the verdict, not just whether other evidence was sufficient.
Whether error was harmless under corrected standard	Bigbear argued the erroneously admitted video had persuasive, prejudicial impact and was not harmless; the jury could have been influenced by inadmissible details.	State emphasized the overwhelming evidence of guilt from multiple eyewitnesses and consistent testimony, making the error harmless.	Despite the court of appeals' error, the Supreme Court found the admission of the interview was harmless given the strong and consistent evidence of guilt.

State v. Jaros, 932 N.W.2d 466 (Minn. 2019) (sets standard for harmless-error review—whether the error significantly affected the verdict)
State v. Smith, 940 N.W.2d 497 (Minn. 2020) (articulates non-exclusive factors for assessing harmless error)
State v. Expose, 872 N.W.2d 252 (Minn. 2015) (clarifies harmless-error review does not merely look at evidence sufficiency)
State v. Blasus, 445 N.W.2d 535 (Minn. 1989) (harmless error may exist even if evidence is otherwise sufficient; error requires new trial if it prejudiced a close case)
State v. Koppi, 798 N.W.2d 358 (Minn. 2011) (harmless-error review is not merely a sufficiency inquiry)
State v. Juarez, 572 N.W.2d 286 (Minn. 1997) (overwhelming evidence of guilt is key in harmless-error analysis)