Minnesota Supreme Court, 1980

State v. Bolts

Minnesota Supreme Court · Decided February 15, 1980 · Wahl

288 N.W.2d 718; 1980 Minn. LEXIS 1309 (North Western Reporter, Second Series)

Counsel

C. Paul Jones, Public Defender, and J. Christopher Cuneo, Asst. Public Defender, Minneapolis, for appellant., Warren Spannaus, Atty. Gen., St. Paul, Thomas L. Johnson, County Atty., Vernon E. Bergstrom, Chief, Appellate Division, David W. Larson, and Thomas A. Weist and Janeen E. Rosas, Asst. County Attys., Minneapolis, for respondent.

Can I rely on this case?

Citation treatment has not been reviewed for this case. The notes below come from the citation graph and the Minnesota Revisor's amendment records, not from a review of how later courts treated this decision.

(as of 9/30/2026)

Last cited by a Minnesota appellate court in 2006, among the opinions in this site’s citation index.

Cites Minnesota statutes amended since this decision

Minn. Stat. § 609.625 — amended 1984

Amendment history from the Minnesota Revisor of Statutes. A later amendment does not necessarily affect this decision's analysis — check the current statute text.

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Minnesota statutes cited

Sections of the Minnesota Statutes this opinion cites.

Minn. Stat. § 609.625

Cases that cite this one

19 later published cases cite this decision.

State v. Ness (Minn. 2006)
State v. Champion (Minn. Ct. App. 1987)
State v. Perez (Minn. Ct. App. 1986)
State v. Lynch (Minn. 1999)
State v. Kennedy (Minn. 1998)
State v. Flores (Minn. 1988)
State v. Norris (Minn. 1988)
State v. Rainer (Minn. 1987)
State v. Doughman (Minn. 1986)
State v. Jones (Minn. 1986)
State v. Rothering (Minn. Ct. App. 1986)
State v. DeBaere (Minn. 1984)
State v. Coles (Minn. 1983)
State v. Filippi (Minn. 1983)
State v. Nelson (Minn. 1982)
State v. Weibel (Minn. 1982)
State v. Morrison (Minn. 1981)
State v. Hinkle (Minn. 1981)
State v. Makela (Minn. 1981)

This list shows which later cases cite this one. It does not say how they treated it, and no review of that has been done. Not a substitute for Shepard’s or KeyCite — verify before relying.

Opinion

WAHL, Justice.

Defendant was found guilty by a district court jury of aggravated forgery, Minn. Stat. § 609.625, subd. 3 (1978), for uttering a forged payroll check which had been stolen from a locked desk in the manager’s office in the parking ramp where defendant worked. Defendant, who was sentenced by the trial court to a maximum prison term of 10 years, contends on this appeal from judgment of conviction that (1) the trial court prejudicially erred in admitting evidence showing that on three prior occasions — once in 1974 and twice in 1977 — defendant had committed similar crimes, and (2) the evidence of his guilt was legally insufficient. We affirm.

Defendant makes a number of arguments in support of his contention that the trial court abused its discretion in admitting the other-crime evidence, which showed that on each prior occasion defendant had taken checks belonging to people he knew and then had negotiated them at liquor establishments where he was known. Without discussing each of defendant’s arguments, we hold that the trial court properly admitted the evidence because the evidence of defendant’s participation in the offenses was clear and convincing, the evidence was relevant, and the probative character of the evidence outweighed its potential for unfair prejudice. While one of the prior crimes occurred 4 years earlier, something which normally might render the evidence irrelevant, in this instance the evidence was still relevant because defendant had been in prison for most of one of the years in the 4-year interval and had committed two similar crimes during the last year of the 4-year interval. In other words, the evidence showed a pattern of similar conduct by defendant. See, in this regard, State v. Anderson, 275 N.W.2d 554 (Minn. 1978) (admission of 6-year-old prior crime as Spreigl evidence where it was part of a continuing pattern of conduct). In summary, we hold that the trial court did not abuse its discretion in admitting the other-crime evidence to prove identity.

There is no merit to defendant’s contention that the evidence of his guilt was legally insufficient.

Affirmed.

Case-law data current through September 30, 2026. Source: CourtListener bulk data.