State of Minnesota v. Jamie Charlotte Blahowski, A16-98

On Jan. 1, 2015, Officer Fiebelkorn stopped Jamie Blahowski for driving with a revoked license and observed a baggie of crystalline substance; backup located the baggie and testing showed 0.041 g methamphetamine.
Blahowski resisted removal from the vehicle; she was handcuffed and charged with fifth-degree controlled-substance crime (possession), obstruction, and driving after revocation.
At trial Blahowski testified and denied possessing methamphetamine. On cross-examination the state sought to impeach her with a 2005 misdemeanor theft conviction.
The district court allowed impeachment by reference to the theft conviction over Blahowski’s objection; she acknowledged the conviction on cross-examination.
The jury found her guilty of the controlled-substance offense; she was sentenced to 12 months and 1 day.
On appeal Blahowski argued the district court erred in admitting the misdemeanor theft conviction for impeachment under Minn. R. Evid. 609(a)(2).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether district court erred in allowing impeachment with 2005 misdemeanor theft under Minn. R. Evid. 609(a)(2)	Blahowski: court admitted conviction without determining the theft involved dishonesty or false statement	State: impeachment was proper; any objection was limited and appellate review should be for plain error	Court: district court failed to make the required specific finding, but any error was harmless — no reasonable likelihood the impeachment affected the verdict

State v. Williams, 771 N.W.2d 514 (2009) (standard of appellate review for admitting prior convictions)
State v. Hill, 801 N.W.2d 646 (2011) (review standard for impeachment by prior conviction)
State v. Zornes, 831 N.W.2d 609 (2013) (application of Rule 609(a) to defendants who testify)
State v. Bettin, 295 N.W.2d 542 (1980) (convictions involving dishonesty admissible without Rule 403 balancing)
State v. Ross, 491 N.W.2d 658 (1992) (analysis whether manner of committing crime involved deceit)
State v. Sims, 526 N.W.2d 201 (1994) (theft may or may not involve dishonesty depending on circumstances)
State v. Bolte, 530 N.W.2d 191 (1995) (factors for assessing prejudice from erroneously admitted evidence)
State v. Finch, 865 N.W.2d 696 (2015) (harmless-error/plain-error substantial-rights standard)
State v. Thao, 875 N.W.2d 834 (2016) (presumption that juries follow limiting instructions)