State v. Hokanson, 821 N.W.2d 340

Hokanson was convicted by a jury of first-degree murder while committing malicious punishment of a child with a past pattern of child abuse in the death of Nicholas Miller.
The State presented extensive evidence of injuries and abusive conduct; Hokanson admitted to shaking Nicholas and restraining him, with various other witnesses testifying.
Hokanson sought access to social services and child-protection records to support an alternative-perpetrator defense, prompting in camera review under Paradee.
The district court disclosed some protected social services documents but limited access and refused certain untethered disclosures.
The State moved in limine to exclude certain CHIPS and other family-history evidence; the court barred some as irrelevant or inappropriate as character evidence, and limited reverse-Spreigl evidence.
On appeal, Hokanson challenged the evidence, instructions, and counsel’s effectiveness; the court affirmed the conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Right to access social services records	Hokanson	Hokanson	District court did not abuse discretion
Admissibility of reverse-Spreigl evidence	Hokanson	Hokanson	No reversible error; evidence properly limited
Sufficiency of circumstantial evidence for past pattern	Hokanson	Hokanson	Sufficient evidence supports past pattern finding
Jury instructions on past pattern of child abuse	Hokanson	Hokanson	Instructions were not plainly erroneous
Ineffective assistance for failing to object to instructions	Hokanson	Hokanson	No ineffective-assistance error; record supports denial

State v. Paradee, 403 N.W.2d 640 (Minn. 1987) (in camera review to balance privacy and defense access)
State v. Hummel, 483 N.W.2d 68 (Minn. 1992) (defendant must show material favorable information for access)
State v. Evans, 756 N.W.2d 854 (Minn. 2008) (abuse of discretion standard for data-disclosure limits)
State v. Atkinson, 774 N.W.2d 584 (Minn. 2009) (two-step test for admissibility of alternative perpetrator evidence)
State v. Johnson, 773 N.W.2d 81 (Minn. 2009) (pattern requires two instances beyond a reasonable doubt)
State v. Andersen, 784 N.W.2d 320 (Minn. 2010) (circumstantial-evidence framework for past-pattern claims)
State v. Matthews, 800 N.W.2d 629 (Minn. 2011) (clarifies reliance on circumstantial proofs and inference standards)
State v. Tscheu, 758 N.W.2d 849 (Minn. 2008) (explains circumstantial-evidence inference requirements)
State v. King, 622 N.W.2d 800 (Minn. 2001) (harms standard for harmless-error review in criminal cases)
State v. Griller, 583 N.W.2d 736 (Minn. 1998) (plain-error test components and fairness considerations)
State v. Laine, 715 N.W.2d 425 (Minn. 2006) (plain-error review thresholds for unobjected instructions)