Standard of review for evidentiary rulings

Evidentiary rulings are reviewed under an abuse of discretion standard.  State v. Edwards, 485 N.W.2d 911 (Minn. 1992).  In order to warrant reversal, however, any error must have affected the substantial rights of the party claiming error. This is what is referred to as the harmless error rule.  The harmless error rule is embodied in Rule 103(a), which states: “[e]rror may not be predicated upon a ruling which admits or excludes evidence unless a substantial right of the party is affected…”

When no objection is made, appellate courts can still review the trial court’s decision, but they do so under a plain error standard.  See Minnesota Rule of Evidence 103(d).  The plain error analysis inquires whether (1) there was an error; (2) the error was plain, and (3) the error affected a party’s substantial rights.  State v. Griller, 583 N.W.2d 736, 740 (Minn. 1998).  If the three prongs are met, a court will address whether action is necessary to ensure fairness and integrity of judicial proceedings.  Id.

(photo: © Renate Dodell,