sentence rule (Minnesota) · Go Syfert
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sentence rule in Minnesota

17 Minnesota opinions name it 2 courts 1987–2025 1 in the last five years

The cases below were cited by Minnesota courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (9)

CaseFollowedCited
Washington v. Stategreen
minnctapp · 2014 · cited in 6 Minnesota opinions naming this issue, 2014–2016
2 sentences

2016And “an offender may not avoid the requirements of the postconviction act by simply labeling a challenge as a motion to correct a sentence under rule 27.03, subdivision 9.” Id. at 212 .

2016But rule 27.03, subdivision 9, “authorizes relief only if a party challenges a sentence, as opposed to a conviction, and only if a party does so by asserting that a sentence is unauthorized by law in the sense that the sentence is contrary to an applicable statute or 4 other applicable law.” Id. at 213 (quotation omitted). “[A]n offender may not avoid the requirements of the postconviction act by simply labeling a challenge as a motion to correct a sentence under rule 27.03, subdivision 9.” Id. at 212 .

36
Townsend v. Stategreen
minn · 2013 · cited in 4 Minnesota opinions naming this issue, 2014–2016
2 sentences

2016State v. Amundson, 828 N.W.2d 747, 751-52 (Minn. App. 2013) (citing Minn. Stat. § 590.04 , subd. 3); see also State v. Stutelberg, 435 N.W.2d 632, 634-35 (Minn. App. 4 1989); cf. Townsend, 834 N.W.2d at 739 (“We have not yet addressed whether the statutory time bar under section 590.01, subdivision 4(a)(2) or the procedural bar under Knaffla apply to a motion to correct a sentence under rule 27.03, subdivision 9.”).

2014The supreme court recently noted, “We have not yet addressed whether the statutory time bar under section 590.01, subdivision 4(a)(2), or the procedural bar under Knaffla apply to a motion to correct a sentence under rule 27.03, subdivision 9.” Townsend, 834 N.W.2d at 739 .

24
Jerome Deon Nunn v. State of Minnesotagreen
minn · 2015 · cited in 1 Minnesota opinions naming this issue, 2025–2025
1 sentence

2025Nunn v. State, 868 N.W.2d 230, 232 (Minn. 2015).

11
State v. Amundsongreen
minnctapp · 2013 · cited in 1 Minnesota opinions naming this issue, 2016–2016
1 sentence

2016State v. Amundson, 828 N.W.2d 747, 751-52 (Minn. App. 2013) (citing Minn. Stat. § 590.04 , subd. 3); see also State v. Stutelberg, 435 N.W.2d 632, 634-35 (Minn. App. 4 1989); cf. Townsend, 834 N.W.2d at 739 (“We have not yet addressed whether the statutory time bar under section 590.01, subdivision 4(a)(2) or the procedural bar under Knaffla apply to a motion to correct a sentence under rule 27.03, subdivision 9.”).

11
State v. Stutelberggreen
minnctapp · 1989 · cited in 1 Minnesota opinions naming this issue, 2016–2016
1 sentence

2016State v. Amundson, 828 N.W.2d 747, 751-52 (Minn. App. 2013) (citing Minn. Stat. § 590.04 , subd. 3); see also State v. Stutelberg, 435 N.W.2d 632, 634-35 (Minn. App. 4 1989); cf. Townsend, 834 N.W.2d at 739 (“We have not yet addressed whether the statutory time bar under section 590.01, subdivision 4(a)(2) or the procedural bar under Knaffla apply to a motion to correct a sentence under rule 27.03, subdivision 9.”).

11
Johnson v. Stategreen
minn · 2011 · cited in 1 Minnesota opinions naming this issue, 2015–2015
1 sentence

2015See Johnson v. State, 801 N.W.2d 173, 176 (Minn. 2011).

11
Bonga v. Stategreen
minn · 2009 · cited in 1 Minnesota opinions naming this issue, 2015–2015
1 sentence

2015See Bonga v. State, 765 N.W.2d 639 , 642–43 (Minn. 2009) (citing cases interpreting the postconviction statute as broad enough to encompass a rule 27.03 motion).

11
United States v. John Robert Andisgreen
ca8 · 2003 · cited in 1 Minnesota opinions naming this issue, 2005–2005
2 sentences

2005See id. at 890-91 .

2005See id. at 890-91 .

11
State v. Coegreen
minnctapp · 1987 · cited in 1 Minnesota opinions naming this issue, 1987–1987
1 sentence

1987State v. Coe, 404 N.W.2d 844, 847 (Minn.App.1987).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Minnesota. Read the followed side critically anyway.

Also cited on this issue (4)

CaseCitedYears
Willie Edd Reynolds v. State of Minnesota green
minn · 2016
1 sentence

2018Second, the district court's jurisdiction did not end when the district court removed Franson's conditional-release term. 4 In Reynolds , the supreme court held that a motion to correct a sentence under rule 27.03, subdivision 9, is an appropriate way to challenge conditional release: a district court exceeds its lawful authority when it imposes a ten-year conditional-release term "on a defendant convicted of failing to register as a predatory offender without the required jury finding or admission by the defendant that the defendant is a risk-level-III offender." 888 N.W.2d at 130 .

12018–2018
State v. Garcia green
minn · 1998
1 sentence

2017Id. at 881 .

12017–2017
State of Minnesota v. Dakari Michael Coles green
minn · 2015
1 sentence

2016Id. at 482 .

12016–2016
State v. Angulo green
minnctapp · 1991
1 sentence

2008Before trial, the State asked the court to add the following sentence to the instruction: “Defendant need not have known or have reason to know that Gerald Vick was a peace officer.” The defendant argued that the instruction was adequate “without that additional language.” The court decided to include the language, and instructed the jury that Evans “need not have known or have reason to know that Gerald Vick was a peace officer.” The district court’s decision to include the instruction was based on State v. Angulo, 471 N.W.2d 570 (Minn.App.1991), rev. denied (Minn. Aug. 2, 1991).

12008–2008

Statutes the citing opinions construe

MN § Minn. Stat. § 480A.08 (12) MN § Minn. Stat. § 590.01 (11) MN § Minn. Stat. § 590.04 (4)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

AL 132 (1890–2025) TN 106 (1976–2025) OH 95 (1992–2026) PA 93 (1919–2026) IL 92 (1909–2026) CA 84 (1898–2026) FL 72 (1947–2016) IN 64 (1880–2020) NC 38 (1796–2025) WA 37 (1918–2025) TX 34 (1927–2024) LA 33 (1917–2018) SC 33 (1975–2025) AZ 26 (1963–2024) MS 24 (1969–2018) GA 23 (1917–2021) NE 21 (1904–2021) NY 20 (1848–2023) MI 17 (1977–2023) IA 17 (1899–2021) MN 17 (1987–2025) KS 14 (1916–2025) NJ 14 (1951–2021) MA 13 (1988–2025) ID 12 (1971–2024) RI 12 (1977–2017) OR 12 (1917–2026) MT 12 (1923–2021) MO 11 (1905–2020) MD 11 (1973–2020) CO 11 (1910–2025) CT 11 (1943–2023) WI 9 (1964–2008) NH 8 (1976–2013) SD 7 (1989–2015) AK 7 (1969–2024) UT 6 (2006–2015) NM 6 (1960–2020) OK 5 (1969–2021) ME 5 (1982–2026) KY 5 (1925–2024) AR 5 (1977–1987) HI 4 (1999–2018) DE 3 (1942–2022) WY 3 (1935–1997) NV 3 (2014–2020) VA 2 (1946–2025) VI 2 (2014–2017) ND 2 (2006–2020)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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