# Smallwood *Defendant in a 1998 Minnesota Court of Appeals reversal arising from Dakota County.* Smallwood is the defendant named in *State v. Smallwood* (Minn. Ct. App. 1998), Dakota County File No. K1-96-2511.[^1] In that appeal the [[Minnesota Court of Appeals]] reversed a first-degree burglary conviction.[^1] The court found that the prosecutor told the jury in opening statement about the defendant's offer to plead guilty, in violation of [[Minn. R. Evid. 410]].[^1] It held that this "denied Smallwood his right to a fair trial."[^1] The project's records list the case as one of two further appellate findings against the Dakota County prosecutor's office. The other is *State v. Pereira* (Minn. Ct. App. Dec. 1999), in which misconduct was found and the conviction was affirmed.[^1][^2] The project's at-issue record names the [[county attorney]] of record in *Smallwood* as [[Backstrom]].[^1] ## Who Smallwood appears in the record only as the named defendant in the 1998 appeal.[^1] The record carries no further identifying detail about the defendant, and none is stated here. The finding concerns the conduct of the prosecution, not the defendant. The project's at-issue record gives Backstrom as the county attorney of record.[^1] ## What The Court of Appeals reversed Smallwood's first-degree burglary conviction.[^1] The ground for reversal was the prosecutor's disclosure to the jury, during opening statement, of the defendant's offer to plead guilty. The court treated that disclosure as a violation of Minn. R. Evid. 410.[^1] The court held that the disclosure "denied Smallwood his right to a fair trial."[^1] ## When The decision is a 1998 opinion of the Minnesota Court of Appeals.[^1] The record does not carry the month and day of the decision. ## Where The prosecution was brought in Dakota County under File No. K1-96-2511.[^1] The appeal was decided by the Minnesota Court of Appeals.[^1] ## How The violation occurred at the start of trial, in the prosecutor's opening statement to the jury.[^1] The record does not establish how the reference to the plea offer came to be made. ## In the at-issue record The project's at-issue record carries the case as row AI-Dakota-010 in its Dakota County package. The row rests on a single court source.[^1] The row pairs the 1998 reversal with a March 2026 presidential action, *Establishing the Task Force to Eliminate Fraud*.[^3] The court's holding, as the record describes it, addresses the effect of the disclosure on the fairness of the trial. It does not address the prosecutor's intent.[^1] The same dossier section lists *State v. Pereira* alongside *Smallwood*. In *Pereira*, a Dakota County case decided in December 1999, the Court of Appeals found prosecutorial misconduct.[^2] The misconduct found was a misstatement of evidence and unsupported statements about the victim's mistrust of the legal system.[^2] The court affirmed the conviction on harmless-error grounds.[^2] ## Notes [^1]: Minnesota Court of Appeals, *State v. Smallwood* (1998), Dakota County File No. K1-96-2511 — reverses a first-degree burglary conviction; holds that the prosecutor's opening-statement reference to the defendant's offer to plead guilty violated Minn. R. Evid. 410 and "denied Smallwood his right to a fair trial." https://law.justia.com/cases/minnesota/court-of-appeals/1998/1636.html [^2]: Minnesota Court of Appeals, *State v. Pereira* (Dec. 1999), Dakota County — finds prosecutorial misconduct (misstatement of evidence; unsupported statements about the victim's mistrust of the legal system); affirms the conviction on harmless error. https://mn.gov/web/prod/static/lawlib/live/archive/ctapun/9912/108.htm [^3]: The White House, *Establishing the Task Force to Eliminate Fraud* (March 2026) — presidential action cited as the anchor of at-issue row AI-Dakota-010. https://www.whitehouse.gov/presidential-actions/2026/03/establishing-the-task-force-to-eliminate-fraud/