State v. Campbell, 861 N.W.2d 95

Joseph Campbell was convicted by a Ramsey County jury of first-degree premeditated murder (gang-related), first-degree premeditated murder, and second-degree intentional murder for the October 14, 2012 killing of Naressa Turner; sentenced to life without release on the gang-count.
Facts tying Campbell to the scene: witnesses placed him at a gas station wearing a black North Face jacket and a Halloween-style mask; a masked shooter fired multiple .22 shots into the vehicle that killed Turner; Campbell was seen without the jacket about 15 minutes later.
L.H. gave a police interview the day after the shooting identifying a mask match that he later disavowed at trial; the State sought to admit video clips of the interview (Exhibit 106) and transcripts (Exhibit 106-A); defense lodged an unspecified objection at trial.
The trial court admitted the video clips and admitted the transcripts only as a court exhibit to aid listening; no specific ground for the defense objection was placed on the record.
The State introduced Spreigl evidence (a 2009 shots-fired incident) via Officer Colby Bragg; the court gave limiting instructions before and during final instructions; the prosecutor did not emphasize this evidence in closing.
Campbell appealed arguing (1) the L.H. interview was improperly admitted as substantive evidence (should have been only for impeachment), and (2) the 2009 incident was improper Spreigl evidence; the court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admission of L.H.’s recorded police interview as substantive evidence	State: admission was permissible and harmless	Campbell: prior inconsistent statements should be limited to impeachment and not used substantively	Even if erroneous, any error was not plain or prejudicial; harmless given cumulative evidence, limited prosecutor use, and overwhelming guilt evidence
Admission of Spreigl evidence (2009 shots-fired incident)	State: evidence showed familiarity with neighborhood, firearms knowledge, and connection to victim’s associate	Campbell: evidence was irrelevant character-bad-act evidence and prejudicial in a circumstantial case	Admission (if error) was harmless: limiting instructions given, prosecutor did not rely on it, and the other evidence of guilt was overwhelming

State v. Olkon, 299 N.W.2d 89 (Minn. 1980) (guidance on using transcripts of recorded statements as jury aids rather than trial exhibits)
State v. Brown, 792 N.W.2d 815 (Minn. 2011) (appellate review under plain-error when objection ground unclear)
State v. Rossberg, 851 N.W.2d 609 (Minn. 2014) (plain-error review and harmless-error analysis for evidentiary rulings)
State v. Griller, 583 N.W.2d 736 (Minn. 1998) (plain-error standard: error, plain, affects substantial rights, remedy)
State v. Davis, 820 N.W.2d 525 (Minn. 2012) (factors for assessing whether improperly admitted evidence affected verdict)
State v. Blom, 682 N.W.2d 578 (Minn. 2004) (abuse-of-discretion standard for admitting other-crimes evidence)
State v. Kennedy, 585 N.W.2d 389 (Minn. 1998) (Spreigl / other-acts admissibility factors)
State v. Spreigl, 139 N.W.2d 167 (Minn. 1965) (establishing rule prohibiting propensity use of other-crimes evidence)
State v. James, 520 N.W.2d 399 (Minn. 1994) (presumption that jurors follow limiting instructions)
State v. Little, 851 N.W.2d 878 (Minn. 2014) (defendant’s burden to show reasonable likelihood that evidentiary error affected verdict)