WHY THIS MATTERS

Minnesota law allows the admission of domestic-violence relationship evidence, but it does not provide clear or consistent guidance for how that evidence should be applied in homicide cases involving intimate partners. As a result, judges retain broad discretion to admit or exclude documented patterns of prior abuse under general evidentiary rules, even when Minnesota case law recognizes that relationship evidence is critical to showing context, escalation, motive, coercive control, and absence of accident. When that discretion is exercised inconsistently, juries may be asked to decide the most serious cases without understanding the full history of the relationship or the danger the victim was experiencing.

This is not about legality. It is about inconsistency, lack of guidance, and lack of transparency.

⸻ KEY PROBLEMS IDENTIFIED

As seen in Sabrina’s case and in other Minnesota cases, courts have at times:

 1. Applied § 634.20 inconsistently, treating relationship evidence as if it depends on requirements not found in the statute or case law, such as hearsay admissibility, an active relationship at the time of death, or a charged domestic offense.

2. Applied narrow or inconsistent interpretations of “domestic conduct,” excluding evidence that reflects coercive control, threats, digital abuse, or escalating behavior.

3. Excluded temporally proximate evidence—including communications and conduct occurring shortly before a homicide—despite its relevance to escalation, motive, and intent.

4. Misapplied Confrontation Clause analysis, including to a defendant’s own statements, non-testimonial digital communications, or contextual messages offered to explain relationship dynamics rather than prove the truth of the matter asserted.

5. Lacked consistent training on domestic-violence lethality factors, including coercive control, escalation patterns, strangulation indicators, and separation-related homicide risk, resulting in relevant context being discounted as unfairly prejudicial.

6. Restricted explanatory context presented to juries, limiting the ability to explain cycles of abuse or relationship dynamics in a way that reflects survivor realities.

The results?:

• Jurors may view cases as isolated incidents rather than escalating abuse
• Key evidence of coercion, threats, or repeated violence may be excluded
• If a jury acquits, double jeopardy prevents retrial—even if exclusion was wrong

This creates irreversible outcomes.

 These issues do not arise from a lack of authority to admit evidence — they arise from a lack of consistent statutory guidance and accountability in how discretion is exercised.

 

 ⸻ WHAT SABRINA’S LAW WOULD DO: Sabrina’s Law does not change convictions, burdens of proof, or sentencing. It addresses how courts evaluate and explain domestic-violence relationship evidence in intimate-partner homicide cases.

Sabrina’s Law would: 

1. Clarify the application of Minn. Stat. § 634.20 to homicide cases involving intimate partners, regardless of how the charge is labeled.

2. Required Findings

Judges must make specific, on-the-record findings when excluding relationship evidence Must explain:

• Relevance
• Pattern of conduct
• Balancing of probative value vs. prejudice

2. Structured Decision-Making

Courts must consider:

• Frequency of prior acts
• Similarity to the charged offense
• Timing and escalation
• Evidence of coercion or control

3. Jury Guidance (Codification)

Requires clear jury instructions on the limited use of relationship evidence

 

4. Pretrial Appellate Review

Allows prosecutors to seek immediate appellate review before trial
Applies only when:

• Evidence is critical
• Exclusion severely impacts the case
• Prevents errors that cannot be fixed after acquittal

This proposal preserves judicial discretion while promoting clarity, consistency, and transparency.

 ⸻ WHY I’M FIGHTING FOR THIS

Sabrina was my sister. She was a mother, a daughter, and a whole human being whose life cannot be reduced to her final moments. Her relationship reflected a documented pattern of escalating abuse — reports, photos, witness accounts, prior violations, and extensive digital communications in the days leading up to her murder. Yet critical parts of that context were excluded, leaving the jury with a limited and incomplete picture.

 Juries deserve the full context. Victims deserve to have their stories considered. Families deserve transparency.

 

 This reform is not about one case alone. It is about every victim whose truth is filtered or minimized by inconsistent evidentiary application.

Impacts:

1. Increases consistency across courts
   Ensures juries see relevant patterns of abuse
2. Reduces risk of irreversible errors in serious cases
3. Aligns court practice with how domestic violence actually occurs

⸻ WHAT WE ARE ASKING MINNESOTA LAWMAKERS TO DO

Adopt Sabrina’s Law: the Minnesota Domestic-Violence Evidence Reform Act. Stand with victims by ensuring that:

• Relationship evidence is evaluated consistently

• Patterns of abuse are understood

• Judicial decisions are transparent

• Justice reflects truth, not omission