State v. Willis

Minn. R. Evid. 1101 requires application of the Minnesota Rules of Evidence to restitution hearings.After a jury trial, Defendant was found guilty of aggravated forgery. At a restitution hearing, Defendant objected to the admissibility of certain e-mails on hearsay grounds. The trial court overruled the objection, concluding that the Rules of Evidence did not apply. The court of appeals affirmed the district court’s evidentiary rulings, concluding that the evidentiary rules do not apply to restitution hearings because the obligation to pay restitution is a part a sentence and the Rules of Evidence do not apply to sentencing proceedings. The Supreme Court reversed, holding that the Rules of Evidence apply to all cases and proceedings unless the rules provide otherwise, and because the language of rule 1101(b)(3) does not preclude their application to restitution hearings, the Minnesota Rules of Evidence apply to such hearings. View "State v. Willis" on Justia Law