State of Minnesota v. Joseph Bullhead, A15-1828

Defendant Joseph Bullhead, the stepfather, was charged and convicted of second-degree criminal sexual conduct for an incident when victim N.E. was in eighth grade; jury found him guilty and sentence imposed.
The State sought and the district court admitted "relationship evidence" under Minn. Stat. § 634.20 describing other sexual and abusive conduct by Bullhead against N.E. (younger incidents) and against another stepdaughter, R.E. (middle-school–age sexual abuse and threats).
The trial court repeatedly gave cautionary limiting instructions that the relationship evidence was admitted only to provide context and not to prove character or propensity.
Bullhead moved to sever counts involving R.E.; the district court granted severance, but testimony about R.E.’s abuse was later admitted as relationship evidence in the trial concerning N.E.
On appeal, Bullhead argued the district court abused its discretion by admitting the relationship evidence under § 634.20 and that the unfair prejudice required a new trial; the Court of Appeals affirmed the conviction.

Issue	State's Argument	Bullhead's Argument	Held
Whether the district court abused its discretion in admitting relationship evidence under Minn. Stat. § 634.20	Evidence of domestic conduct by the accused against other family members is admissible to show context and similar conduct; probative value outweighs prejudice	The evidence was unfairly prejudicial, essentially propensity/Spreigl evidence that should have been excluded	Court: No abuse of discretion; evidence admissible under § 634.20 because it was probative of similar conduct and context
Whether admission of relationship evidence unduly prejudiced the defendant requiring a new trial	Repeated cautionary instructions mitigated any risk of unfair prejudice; jurors presumed to follow instructions	The R.E. evidence was more egregious, cumulative, and highly prejudicial (used to show conformity); severance made its admission improper and likely affected the verdict	Court: No undue prejudice shown; limiting instructions and probative value meant no new trial needed

State v. Matthews, 779 N.W.2d 543 (Minn. 2010) (standard of review for evidentiary rulings)
State v. Amos, 658 N.W.2d 201 (Minn. 2003) (defendant bears burden to show abuse of discretion and prejudice)
State v. Fraga, 864 N.W.2d 615 (Minn. 2015) (§ 634.20 is a rule of evidence governing relationship evidence)
State v. Loving, 775 N.W.2d 872 (Minn. 2009) (review of district court evidentiary rulings for abuse of discretion)
State v. McCoy, 682 N.W.2d 153 (Minn. 2004) (domestic abuse often occurs in privacy and may involve patterns warranting different treatment for relationship evidence)
State v. Ness, 707 N.W.2d 676 (Minn. 2006) (Spreigl framework and concerns about propensity evidence and unfair prejudice)
State v. Barnslater, 786 N.W.2d 646 (Minn. App. 2010) (courts should instruct juries on proper use of § 634.20 evidence)
State v. Ware, 856 N.W.2d 719 (Minn. App. 2014) (limiting instructions lessen undue weight of relationship evidence)
State v. Miller, 573 N.W.2d 661 (Minn. 1998) (presumption that jurors follow judicial instructions)
State v. Caldwell, 322 N.W.2d 574 (Minn. 1982) (cautionary instructions may not always cure prejudice from improperly admitted evidence)