State v. Zinski, 927 N.W.2d 272

Defendant Danny Lee Zinski was convicted of first‑degree burglary and fourth‑degree criminal sexual conduct based on an incident involving his ex‑girlfriend D.S.; trial evidence included testimony of prior verbal and physical abuse admitted under Minn. Stat. § 634.20 (1996).
The district court admitted § 634.20 "relationship" evidence but did not give a limiting instruction sua sponte, and defense counsel did not request one or object to the final instructions.
Zinski appealed, arguing plain error from the court’s failure to sua sponte instruct the jury about the proper use of § 634.20 evidence; the court of appeals agreed and ordered a new trial.
The State petitioned for review to the Minnesota Supreme Court, which granted review to resolve a conflict in appellate authority about whether sua sponte limiting instructions are required for § 634.20 evidence.
The Supreme Court held that appellate plain‑error review must assess the law as of appellate review and found the law unsettled at that time, so the court of appeals erred in finding plain error; it reversed the court of appeals.
The Court also announced a prospective rule clarifying that for trials after this opinion, when § 634.20 relationship evidence is admitted over a defendant’s objection, the district court must sua sponte instruct the jury on proper use of that evidence unless the defendant objects to that instruction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court plainly erred by failing to sua sponte give a limiting instruction for § 634.20 evidence	State: No plain error because precedent was unsettled at time of appellate review	Zinski: Failure to give limiting instruction contravened precedent and is plain error	Court: No plain error; law was unsettled at time of appellate review, so forfeiture not excused; reversed court of appeals
Whether to clarify rule going forward about sua sponte limiting instructions for § 634.20 evidence	State: Ask reversal and clarification that requirement was not clearly established at time of appeal	Zinski: Maintain court of appeals’ approach; limiting instruction should be required sua sponte	Court: Adopt prospective rule: for trials after this opinion, when § 634.20 evidence is admitted over defendant’s objection, court must sua sponte instruct jury on proper use unless defendant objects to the instruction

State v. McCoy, 682 N.W.2d 153 (Minn. 2004) (adopted § 634.20 as a rule of evidence and explained how relationship evidence differs from other Spreigl evidence)
State v. Bauer, 598 N.W.2d 352 (Minn. 1999) (discussed limiting instructions for "relationship"/404(b) evidence; language characterized as advisory rather than mandatory)
State v. Williams, 593 N.W.2d 227 (Minn. 1999) (addressed limiting instructions for prior‑abuse evidence; held no plain error in that case)
State v. Word, 755 N.W.2d 776 (Minn. App. 2008) (court of appeals held failure to sua sponte give limiting instruction for § 634.20 evidence was plain error)
State v. Meldrum, 724 N.W.2d 15 (Minn. App. 2006) (court of appeals urged cautionary instructions for § 634.20 evidence upon admission and in final charge)
State v. Melanson, 906 N.W.2d 561 (Minn. App. 2018) (court of appeals held failure to sua sponte give limiting instruction for § 634.20 evidence was not plain error; created conflict with earlier appellate decisions)
State v. Kelley, 855 N.W.2d 269 (Minn. 2014) (plain‑error analysis examines law as it exists at time of appellate review)
State v. Taylor, 869 N.W.2d 1 (Minn. 2015) (analogized limiting‑instruction obligations for prior‑conviction/Spreigl contexts and held no sua sponte requirement)