State of Minnesota, Appellant v. Scott Wade Ramey, Respondent

Summary

The court held that plain-error review governs unobjected-to prosecutorial misconduct claims. The defendant must show that misconduct occurred and was plain, but once that showing is made, the state must demonstrate that the misconduct did not affect the defendant's substantial rights. The court therefore reversed and remanded for the court of appeals to apply that framework to the prosecutor's closing argument. Justices Gildea, Paul H. Anderson, and G. Barry Anderson concurred in the result but contested shifting the prejudice burden to the state.