State of Minnesota v. Timothy Lee Heller

Syllabus

1. The alleged error in a venue instruction was harmless beyond a reasonable doubt. 2. Evidence of several singular acts of abuse committed against different individual victims constitutes a past pattern of domestic abuse under Minnesota Statutes section 609.185(a)(6) (2022). 3. The district court did not abuse its discretion in admitting evidence of a prior instance of abuse to prove a past pattern of domestic abuse under Minnesota Statutes section 609.185(a)(6) (2022) because the prior instance of abuse was connected to a steady or continuous pattern of abusive behavior that shows it is the defendant's regular way of acting and, accordingly, it was not too remote. 4. The district court abused its discretion in admitting expert witness testimony on domestic violence screening lethality factors, but the admission of the evidence was harmless error. 5. The district court did not err in excluding certain purported alternative- perpetrator-related evidence. Affirmed.