State of Minnesota v. David Muniz Bustos

The majority concludes, and I agree, that a past pattern of domestic abuse may be proven, as is the case here, by incidents of domestic abuse against more than one victim. I also agree that the district court utilized the term “any” in an ambiguous manner when it precluded defense counsel from arguing that the State was required to prove “any” alleged incident of prior domestic abuse beyond a reasonable doubt. I disagree, however, that this ambiguous use of the term “any,” when combined with any error in the definition of domestic abuse provided to the jury by the district court, was a plain…