State v. Brown, 792 N.W.2d 815

Brown was convicted of attempted second-degree murder and possession of a pistol without a permit after a June 14, 2006 confrontation involving Brown, M.L., and Brown’s girlfriend during a child-visitation dispute.
Brown testified he had a pistol permit in omnibus proceedings; at trial he admitted not having a permit for the pistol used.
During cross-examination Brown admitted he did not have a permit; the State impeached him with an omnibus-hearing statement that he had a permit.
Brown argued the omnibus statement should be excluded under Minn. R. Evid. 410 because it was made in connection with a plea offer.
The district court allowed the omnibus statement to be elicited at trial; trial included self-defense and defense of others claims.
The court of appeals affirmed; the Minnesota Supreme Court reversed and remanded for a new trial on the attempted-murder charge.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Rule 410 bars the omnibus statement.	Brown argues the omnibus statement was inadmissible under Rule 410.	State contends the statement falls within Rule 410 as an offer/connection to plea discussions.	Yes; admission was rule 410 error.
Whether the error was plain.	Brown maintains the error contravenes Rule 410.	State argues the error was not plain or obvious.	Yes; the error was plain.
Whether the error affected Brown’s substantial rights and the verdict.	Admissibility impacted credibility and the self-defense claim.	Evidence would not have changed outcome; trial could stand.	Yes; substantial rights affected, likelihood of prejudice.”},{
Whether the error seriously affected the fairness of the proceedings.	Admission undermines fairness and integrity of proceedings.	Trial integrity unaffected beyond concrete issue.	Yes; new trial required.

State v. Blom, 682 N.W.2d 578 (Minn. 2004) (plain-error review under evidentiary rulings; Rule 410 context)
State v. Griller, 583 N.W.2d 736 (Minn. 1998) (four-factor plain-error analysis)
State v. Reed, 737 N.W.2d 572 (Minn. 2007) (substantial-rights; four-factor test application)
State v. Strommen, 648 N.W.2d 681 (Minn. 2002) (plain-error framework; effect on verdict)