# Minn. R. Evid. 410 *Minnesota rule of evidence concerning a defendant's offer to plead guilty.* Minn. R. Evid. 410 is one of the Minnesota Rules of Evidence. In *State v. Smallwood* (1998), the [[Minnesota Court of Appeals]] reversed a first-degree burglary conviction from Dakota County. It held that the prosecutor had violated Rule 410 by telling the jury, in opening statement, about the defendant's offer to plead guilty.[^1] The court held that the violation "denied Smallwood his right to a fair trial." The [[county attorney]] of record in the prosecution was [[Backstrom]].[^1] The project's at-issue record pairs the *Smallwood* reversal with a March 2026 White House presidential action, *Establishing the Task Force to Eliminate Fraud*, which the entry names as its federal anchor.[^2] ## Who - The defendant was [[Smallwood]]. The prosecution was brought in Dakota County, and the county attorney of record was Backstrom.[^1] - The reversing court was the Minnesota Court of Appeals.[^1] ## What - The prosecutor told the jury in opening statement that the defendant had offered to plead guilty. The court of appeals found that this violated Minn. R. Evid. 410.[^1] - The court held that the violation "denied Smallwood his right to a fair trial." It reversed the first-degree burglary conviction.[^1] - The opinion records the violation and the reversal. It does not establish why the statement was made in opening.[^1] ## When - The Minnesota Court of Appeals decided *Smallwood* in 1998.[^1] ## Where - The case arose in Dakota County, [[Minnesota]], under Dakota County File No. K1-96-2511.[^1] ## In the at-issue record At-issue entry AI-Dakota-010 sets the 1998 *Smallwood* reversal beside the Dakota County office of the county attorney of record, Backstrom. The entry draws its account of the case from the *Smallwood* opinion.[^1] The entry's federal anchor is the White House presidential action of March 2026, *Establishing the Task Force to Eliminate Fraud*.[^2] ## Notes [^1]: Minnesota Court of Appeals, *State v. Smallwood* (1998), Dakota County File No. K1-96-2511. The opinion establishes that the prosecutor violated Minn. R. Evid. 410 by telling the jury in opening statement about the defendant's offer to plead guilty, that this "denied Smallwood his right to a fair trial," and that the first-degree burglary conviction was reversed. https://law.justia.com/cases/minnesota/court-of-appeals/1998/1636.html [^2]: The White House, *Establishing the Task Force to Eliminate Fraud* (March 2026). Presidential action named as the federal anchor of at-issue entry AI-Dakota-010. https://www.whitehouse.gov/presidential-actions/2026/03/establishing-the-task-force-to-eliminate-fraud/