In a Minnesota felony or gross-misdemeanor case, the most important day often isn’t the trial — it’s the omnibus hearing, where the court decides what evidence the jury will hear and whether there’s enough to make the defendant stand trial at all. If you’ve heard the terms “Rasmussen hearing,” “Spreigl notice,” or “Florence hearing,” these are Minnesota-specific names for issues decided at or around that hearing. This page explains each one in plain language and how they fit together — because what happens here frequently decides the case.
The omnibus hearing — the hub
In felony and gross-misdemeanor cases where the defendant hasn’t pleaded guilty, the rules require an omnibus hearing (Rule 11). “Omnibus” means “many in one” — historically, several separate pretrial motions were combined into a single hearing. At the omnibus hearing the court can decide a wide range of pretrial issues: probable cause, suppression of evidence, the admissibility of certain evidence, and discovery disputes. When the defense actually contests issues that require testimony or evidence, it becomes a contested omnibus hearing — essentially the evidentiary battleground of the pretrial phase.
A critical rule: issues you don’t raise at the omnibus hearing are generally waived (with narrow exceptions like jurisdiction). So the omnibus hearing is also where the defense must preserve issues for trial and appeal. The court generally must issue its findings within 30 days of taking the issues under advisement.
The Rasmussen hearing — suppressing evidence
Named for State ex rel. Rasmussen v. Tahash, a Rasmussen hearing is the part of the omnibus hearing that deals with constitutional challenges to the admissibility of evidence — primarily motions to suppress evidence obtained through search and seizure, or statements/confessions, or identification procedures. The State gives a “Rasmussen notice” of the evidence it intends to use that was obtained from the defendant or through identification procedures, and the defense can demand a hearing to challenge it.
This is where the “fruit of the poisonous tree” fight happens: if police obtained evidence by violating your rights, a successful Rasmussen challenge can get that evidence suppressed — and if the suppressed evidence is central, the case can collapse. This is one of the most powerful tools the defense has.
The Spreigl notice — keeping out prior bad acts
Named for State v. Spreigl, “Spreigl evidence” is Minnesota’s term for evidence of other crimes, wrongs, or acts by the defendant — the kind of “he did something similar before” evidence that can unfairly prejudice a jury. Under the rules, if the prosecution wants to use such evidence, it must give a Spreigl notice (generally by the omnibus hearing), so the admissibility can be litigated before trial.
This matters enormously because prior-bad-acts evidence is often devastating and frequently improper. Fighting a Spreigl notice — keeping the jury from hearing about unrelated past conduct — can be as important as any suppression motion. It connects closely to a motion in limine on the same subject.
The Florence hearing — testing whether the case should proceed
Named for State v. Florence, a Florence hearing is a contested probable cause hearing — a challenge to whether the complaint contains enough to require the defendant to stand trial. The test isn’t whether police had probable cause to arrest; it’s whether, taking the record in the light most favorable to the State, the facts reasonably support the charge. As Florence framed it, a complaint must be dismissed if the facts, even taken in the State’s favor, do not reasonably tend to support the defendant’s guilt.
Importantly, this is usually decided on the written record — the judge assumes the State’s facts are true and asks whether they’re legally enough. It can be used to argue that the facts support only a lesser charge, or that the alleged conduct doesn’t actually amount to the crime charged. Because the flow of the rules contemplates probable cause as typically the last omnibus issue decided, the Florence/probable-cause determination often comes after suppression and discovery are resolved.
How they fit together
Here’s the sequence in a typical contested felony case: the State provides its Rasmussen and Spreigl notices; the defense demands a hearing on the issues it wants to contest; discovery is completed; and then, at the (contested) omnibus hearing, the court resolves suppression (Rasmussen), the admissibility of prior-acts evidence (Spreigl), any other evidentiary issues, and finally probable cause (Florence). Win the right combination of these, and the case can be dismissed or gutted before a jury is ever picked — which is exactly why the pretrial phase is where so many cases are truly decided.
Related: the right to a jury trial in Minnesota criminal cases.
Updated May 18, 2026 · Law verified as of June 17, 2026. This article is general information about Minnesota law, not legal advice.
Frequently Asked Questions
What is a Rasmussen hearing in Minnesota?
It is the part of the omnibus hearing that addresses constitutional challenges to the admissibility of evidence — primarily motions to suppress evidence from a search or seizure, statements or confessions, or identification procedures. It is named for State ex rel. Rasmussen v. Tahash . If the challenge succeeds, key evidence can be suppressed.
What is Spreigl evidence?
Spreigl evidence is evidence of a defendant’s other crimes, wrongs, or acts — named for State v. Spreigl . Because such evidence can unfairly prejudice a jury, the prosecution must give a Spreigl notice (generally by the omnibus hearing) so its admissibility can be litigated before trial.
What is a Florence hearing?
A Florence hearing is a contested probable cause hearing testing whether the complaint contains enough to require the defendant to stand trial. Named for State v. Florence , the standard is whether the facts, taken in the light most favorable to the State, reasonably support the charge. It is usually decided on the written record.
What is the omnibus hearing?
In felony and gross-misdemeanor cases where the defendant has not pleaded guilty, the omnibus hearing (Rule 11) is the combined pretrial hearing where the court decides issues like probable cause, suppression, evidentiary questions, and discovery disputes. When issues are actually contested with evidence, it becomes a contested omnibus hearing. Issues not raised there are generally waived.
Why are these hearings so important?
Because they decide what evidence the jury can hear and whether the case proceeds at all. A successful suppression (Rasmussen) or probable-cause challenge (Florence) can end or gut a case before trial, and excluding prior-acts evidence (Spreigl) can dramatically change what a jury hears. Many cases are effectively won or lost at this stage.
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Read the guideThe information on this article is for general informational purposes only and is not legal advice. Reading this article does not create an attorney-client relationship.