ex post facto clause (Minnesota) · Go Syfert
← Minnesota issues

ex post facto clause in Minnesota

15 Minnesota opinions name it 2 courts 1985–2026 4 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 (29)

CaseFollowedCited
Lynce v. Mathisgreen
scotus · 1997 · cited in 2 Minnesota opinions naming this issue, 2006–2024
2 sentences

2024Lynce v. Mathis, 519 U.S. 433, 441 (1997); Rew, 845 N.W.2d at 789-90 .

2006“It is axiomatic that for a law to be ex post facto it must be more onerous than the prior law.” Dobbert, 432 U.S. at 294 , 97 S.Ct. 2290 ; see also Lynce, 519 U.S. at 441 , 117 S.Ct. 891 .

22
Hankerson v. Stategreen
minn · 2006 · cited in 2 Minnesota opinions naming this issue, 2016–2024
2 sentences

2024See Hankerson v. State, 723 N.W.2d 232, 241-42 (Minn. 2006) (citing Dobbert v. Florida, 432 U.S. 282, 292-94 (1977) (holding that changing the roles of judge and jury was procedural and, therefore, not an ex post facto violation)).

2016A law can work to a defendant’s disadvantage and thereby violate the ex post facto clause in four ways: “(1) by punishing as a crime an act previously committed, which was innocent when done; (2) by making more burdensome the punishment for a crime, after its commission[;] (3) by depriving one charged with [a] crime of any defense available according to law at the time when the act was committed,” Hankerson, 723 N.W.2d at 241 (internal quotation marks omitted); and (4) by “changing] the rules of evidence [so that] less or different testimony is sufficient to convict than was then required,” su

22
United States v. Elrodgreen
ca7 · 1982 · cited in 2 Minnesota opinions naming this issue, 1994–1999
2 sentences

1994See, e.g., United States v. Brechtel, 997 F.2d 1108, 1113 (5th Cir.1993) (retroactive extension of the limitations period does not violate the ex post facto clause), cert. denied, - U.S. -, 114 S.Ct. 605 , 126 L.Ed.2d 570 (1993); United States v. Taliaferro, 979 F.2d 1399, 1403 (10th Cir.1992) (congress has the authority to extend a statute of limitations where the original time period has not run); United States v. Knipp, 963 F.2d 839, 844 (6th Cir.1992) (extension of a limitations period before that period has run does not violate the ex post facto clause); United States v. Madia, 955 F.2d 5

1994See, e.g., United States v. Brechtel, 997 F.2d 1108, 1113 (5th Cir.1993) (retroactive extension of the limitations period does not violate the ex post facto clause), cert. denied, ___ U.S. ___, 114 S.Ct. 605 , 126 L.Ed.2d 570 (1993); United States v. Taliaferro, 979 F.2d 1399, 1403 (10th Cir.1992) (congress has the authority to extend a statute of limitations where the original time period has not run); United States v. Knipp, 963 F.2d 839, 844 (6th Cir.1992) (extension of a limitations period before that period has run does not violate the ex post facto clause); United States v. Madia, 955 F.

22
State v. Manninggreen
minnctapp · 1995 · cited in 2 Minnesota opinions naming this issue, 2011–2024
2 sentences

2024This court considered the same ex post facto challenge to the registration statute in State v. Manning, 532 N.W.2d 244 (Minn. App. 1995), rev. denied (Minn. July 20, 1995). 11 There, we determined that the statute is regulatory and not punitive because it serves the regulatory purpose of assisting police investigations.

2011See Manning, 532 N.W.2d at 247 (applying the Kennedy factors in an ex post facto challenge to a sex-offender-registration statute).

12
Rew ex rel. T.C.B. v. Bergstromgreen
minn · 2014 · cited in 2 Minnesota opinions naming this issue, 2016–2024
2 sentences

2024Lynce v. Mathis, 519 U.S. 433, 441 (1997); Rew, 845 N.W.2d at 789-90 .

2016Raw v. Bergstrom, 845 N.W.2d 764, 794 (Minn.2014) (quoting State v. Ryan, 13 Minn. 370, 375-76 , 13 Gil. 343 , 348 (1868)).

12
Dobbert v. Floridagreen
scotus · 1977 · cited in 2 Minnesota opinions naming this issue, 2006–2024
2 sentences

2024See Hankerson v. State, 723 N.W.2d 232, 241-42 (Minn. 2006) (citing Dobbert v. Florida, 432 U.S. 282, 292-94 (1977) (holding that changing the roles of judge and jury was procedural and, therefore, not an ex post facto violation)).

2006“It is axiomatic that for a law to be ex post facto it must be more onerous than the prior law.” Dobbert, 432 U.S. at 294 , 97 S.Ct. 2290 ; see also Lynce, 519 U.S. at 441 , 117 S.Ct. 891 .

12
Samuels v. McCurdygreen
scotus · 1925 · cited in 2 Minnesota opinions naming this issue, 1985–1993
2 sentences

1993See Samuels v. McCurdy, 267 U.S. 188 , 45 S.Ct. 264 , 69 L.Ed. 568 (1925) (no ex post facto violation where defendant convicted for possessing liquor which he had obtained before and held continuously through enactment of prohibition law); State v. Willis, 332 N.W.2d 180 (Minn.1983) (use of prior convictions to increase punishment for offense committed after statutory effective date does not violate ex post facto clause); State v. Howard, 360 N.W.2d 637 (Minn.App.1985) (no ex post facto violation where defendant prosecuted for post-enactment conduct even though conduct began before enactment a

1993See Samuels v. McCurdy, 267 U.S. 188 , 45 S.Ct. 264 , 69 L.Ed. 568 (1925) (no ex post facto violation where defendant convicted for possessing liquor which he had obtained before and held continuously through enactment of prohibition law); State v. Willis, 332 N.W.2d 180 (Minn.1983) (use of prior convictions to increase punishment for offense committed after statutory effective date does not violate ex post facto clause); State v. Howard, 360 N.W.2d 637 (Minn.App.1985) (no ex post facto violation where defendant prosecuted for post-enactment conduct even though conduct began before enactment a

12
State v. Soukupgreen
minnctapp · 2008 · cited in 1 Minnesota opinions naming this issue, 2026–2026
1 sentence

2026See State v. Soukup, 746 N.W.2d 918, 923 (Minn. App. 2008) (stating that a law violates the ex post facto clause “by punishing as a crime an act previously committed, which was not a crime at the time”), rev. denied (Minn. June 18, 2008). 5 containers and also did not challenge the additional three search warrants, issued after the initial search warrant, allowing the search of the contents of his electronic devices.

11
Carmell v. Texasgreen
scotus · 2000 · cited in 1 Minnesota opinions naming this issue, 2016–2016
2 sentences

2016A law can work to a defendant’s disadvantage and thereby violate the ex post facto clause in four ways: “(1) by punishing as a crime an act previously committed, which was innocent when done; (2) by making more burdensome the punishment for a crime, after its commission[;] (3) by depriving one charged with [a] crime of any defense available according to law at the time when the act was committed,” Hankerson, 723 N.W.2d at 241 (internal quotation marks omitted); and (4) by “changing] the rules of evidence [so that] less or different testimony is sufficient to convict than was then required,” su

2016A law can work to a defendant’s disadvantage and thereby violate the ex post facto clause in four ways: “(1) by punishing as a crime an act previously committed, which was innocent when done; (2) by making more burdensome the punishment for a crime, after its commission[;] (3) by depriving one charged with [a] crime of any defense available according to law at the time when the act was committed,” Hankerson, 723 N.W.2d at 241 (internal quotation marks omitted); and (4) by “changing] the rules of evidence [so that] less or different testimony is sufficient to convict than was then required,” su

11
State v. Harringtongreen
minnctapp · 1993 · cited in 1 Minnesota opinions naming this issue, 2011–2011
1 sentence

2011See State v. Harrington, 504 N.W.2d 500, 503 (Minn.App.1993) (rejecting an ex post facto challenge to a harassment restraining order because “[a]lthough the restraining order was based on events occurring before enactment of [the statute], the restraining order did not apply to events occurring before the enactment”), review denied (Minn. Sept. 30, 1993). ' Second, the district court issued the OFP extension because appellant’s contact with his ex-wife was criminal when it was committed under OFPs that existed at the time.

11
State v. Ringgreen
ariz · 2003 · cited in 1 Minnesota opinions naming this issue, 2006–2006
2 sentences

2006Hence, the changes to the state's capital sentencing procedures do not resemble the type of after-the-fact legislative evil contemplated by contemporary understandings of the ex post facto doctrine. 65 P.3d at 928 (citations and footnote omitted). [7] Even if the 2005 amendments did not fall under this procedural law exception, they are not prohibited as ex post facto laws because they do not work to Hankerson's disadvantage.

2006Hence, the changes to the state’s capital sentencing procedures do not resemble the type of after-the-fact legislative evil contemplated by contemporary understandings of the ex post facto doctrine. 65 P.3d at 928 (citations and footnote omitted). 7 Even if the 2005 amendments did not fall under this procedural law exception, they are not prohibited as ex post facto laws because they do not work to Hankerson’s disadvantage.

11
State v. Garciagreen
minnctapp · 2003 · cited in 1 Minnesota opinions naming this issue, 2004–2004
2 sentences

2004See Weaver, 450 U.S. at 28-29 , 101 S.Ct. at 964 ; see also State v. Garcia, 670 N.W.2d 297, 299 (Minn.App.2003) (holding that the 2000 amendment did not violate the ex post facto clause because "[w]hen enacted, the [2000] amendment merely exposed appellant to possible additional punishment in the event of a future probation violation"), review granted (Minn. Dec. 23, 2003); Gasper v. Gunter, 851 P.2d 912, 918 (Co.1993) (holding that application of a statute prohibiting credit for time on parole did not implicate ex post facto prohibition because the forfeiture of jail credit was based on "an

2004See Weaver, 450 U.S. at 28-29 , 101 S.Ct. at 964 ; see also State v. Garcia, 670 N.W.2d 297, 299 (Minn.App.2003) (holding that the 2000 amendment did not violate the ex post facto clause because “[wjhen enacted, the [2000] amendment merely exposed appellant to possible additional punishment in the event of a future probation violation”), review granted (Minn. Dec. 23, 2003); Gasper v. Gunter, 851 P.2d 912, 918 (Co.1993) (holding that application of a statute prohibiting credit for time on parole did not implicate ex post facto prohibition because the forfeiture of jail credit was based on “an

11
Gasper v. Guntergreen
colo · 1993 · cited in 1 Minnesota opinions naming this issue, 2004–2004
2 sentences

2004See Weaver, 450 U.S. at 28-29 , 101 S.Ct. at 964 ; see also State v. Garcia, 670 N.W.2d 297, 299 (Minn.App.2003) (holding that the 2000 amendment did not violate the ex post facto clause because "[w]hen enacted, the [2000] amendment merely exposed appellant to possible additional punishment in the event of a future probation violation"), review granted (Minn. Dec. 23, 2003); Gasper v. Gunter, 851 P.2d 912, 918 (Co.1993) (holding that application of a statute prohibiting credit for time on parole did not implicate ex post facto prohibition because the forfeiture of jail credit was based on "an

2004See Weaver, 450 U.S. at 28-29 , 101 S.Ct. at 964 ; see also State v. Garcia, 670 N.W.2d 297, 299 (Minn.App.2003) (holding that the 2000 amendment did not violate the ex post facto clause because “[wjhen enacted, the [2000] amendment merely exposed appellant to possible additional punishment in the event of a future probation violation”), review granted (Minn. Dec. 23, 2003); Gasper v. Gunter, 851 P.2d 912, 918 (Co.1993) (holding that application of a statute prohibiting credit for time on parole did not implicate ex post facto prohibition because the forfeiture of jail credit was based on “an

11
Weaver v. Grahamgreen
scotus · 1981 · cited in 1 Minnesota opinions naming this issue, 2004–2004
2 sentences

2004See Weaver, 450 U.S. at 28-29 , 101 S.Ct. at 964 ; see also State v. Garcia, 670 N.W.2d 297, 299 (Minn.App.2003) (holding that the 2000 amendment did not violate the ex post facto clause because “[wjhen enacted, the [2000] amendment merely exposed appellant to possible additional punishment in the event of a future probation violation”), review granted (Minn. Dec. 23, 2003); Gasper v. Gunter, 851 P.2d 912, 918 (Co.1993) (holding that application of a statute prohibiting credit for time on parole did not implicate ex post facto prohibition because the forfeiture of jail credit was based on “an

2004See Weaver, 450 U.S. at 28-29 , 101 S.Ct. at 964 ; see also State v. Garcia, 670 N.W.2d 297, 299 (Minn.App.2003) (holding that the 2000 amendment did not violate the ex post facto clause because “[wjhen enacted, the [2000] amendment merely exposed appellant to possible additional punishment in the event of a future probation violation”), review granted (Minn. Dec. 23, 2003); Gasper v. Gunter, 851 P.2d 912, 918 (Co.1993) (holding that application of a statute prohibiting credit for time on parole did not implicate ex post facto prohibition because the forfeiture of jail credit was based on “an

11
State v. Dumasgreen
minnctapp · 1998 · cited in 1 Minnesota opinions naming this issue, 2003–2003
1 sentence

2003See State v. Dumas, 587 N.W.2d 299, 304 (Minn.App.1998) (ex post facto law applies to events occurring before its enactment), review denied (Minn. 24 Feb. 1999).

11
Marks v. United Statesgreen
scotus · 1977 · cited in 1 Minnesota opinions naming this issue, 1995–1995
2 sentences

1995See Marks v. United States, 430 U.S. 188 , 191—92, 97 S.Ct. 990, 992-93 , 51 L.Ed.2d 260 (1977); State v. Welke, 298 Minn. 402, 411 , 216 N.W.2d 641, 648 (1974) (noting that defendant lacked fair notice that materials he sold would be judicially construed as “obscene”).

1995See Marks v. United States, 430 U.S. 188 , 191—92, 97 S.Ct. 990, 992-93 , 51 L.Ed.2d 260 (1977); State v. Welke, 298 Minn. 402, 411 , 216 N.W.2d 641, 648 (1974) (noting that defendant lacked fair notice that materials he sold would be judicially construed as “obscene”).

11
State v. Welkegreen
minn · 1974 · cited in 1 Minnesota opinions naming this issue, 1995–1995
2 sentences

1995See Marks v. United States, 430 U.S. 188 , 191—92, 97 S.Ct. 990, 992-93 , 51 L.Ed.2d 260 (1977); State v. Welke, 298 Minn. 402, 411 , 216 N.W.2d 641, 648 (1974) (noting that defendant lacked fair notice that materials he sold would be judicially construed as “obscene”).

1995See Marks v. United States, 430 U.S. 188 , 191—92, 97 S.Ct. 990, 992-93 , 51 L.Ed.2d 260 (1977); State v. Welke, 298 Minn. 402, 411 , 216 N.W.2d 641, 648 (1974) (noting that defendant lacked fair notice that materials he sold would be judicially construed as “obscene”).

11
People v. Lewisgreen
calctapp · 1986 · cited in 1 Minnesota opinions naming this issue, 1994–1994
11
Chmiel v. Pennsylvaniagreen
scotus · 1993 · cited in 1 Minnesota opinions naming this issue, 1994–1994
2 sentences

1994See, e.g., United States v. Brechtel, 997 F.2d 1108, 1113 (5th Cir.1993) (retroactive extension of the limitations period does not violate the ex post facto clause), cert. denied, - U.S. -, 114 S.Ct. 605 , 126 L.Ed.2d 570 (1993); United States v. Taliaferro, 979 F.2d 1399, 1403 (10th Cir.1992) (congress has the authority to extend a statute of limitations where the original time period has not run); United States v. Knipp, 963 F.2d 839, 844 (6th Cir.1992) (extension of a limitations period before that period has run does not violate the ex post facto clause); United States v. Madia, 955 F.2d 5

1994See, e.g., United States v. Brechtel, 997 F.2d 1108, 1113 (5th Cir.1993) (retroactive extension of the limitations period does not violate the ex post facto clause), cert. denied, ___ U.S. ___, 114 S.Ct. 605 , 126 L.Ed.2d 570 (1993); United States v. Taliaferro, 979 F.2d 1399, 1403 (10th Cir.1992) (congress has the authority to extend a statute of limitations where the original time period has not run); United States v. Knipp, 963 F.2d 839, 844 (6th Cir.1992) (extension of a limitations period before that period has run does not violate the ex post facto clause); United States v. Madia, 955 F.

11
Falter v. United Statesgreen
ca2 · 1928 · cited in 1 Minnesota opinions naming this issue, 1994–1994
2 sentences

1994See, e.g., United States v. Brechtel, 997 F.2d 1108, 1113 (5th Cir.1993) (retroactive extension of the limitations period does not violate the ex post facto clause), cert. denied, - U.S. -, 114 S.Ct. 605 , 126 L.Ed.2d 570 (1993); United States v. Taliaferro, 979 F.2d 1399, 1403 (10th Cir.1992) (congress has the authority to extend a statute of limitations where the original time period has not run); United States v. Knipp, 963 F.2d 839, 844 (6th Cir.1992) (extension of a limitations period before that period has run does not violate the ex post facto clause); United States v. Madia, 955 F.2d 5

1994See, e.g., United States v. Brechtel, 997 F.2d 1108, 1113 (5th Cir.1993) (retroactive extension of the limitations period does not violate the ex post facto clause), cert. denied, ___ U.S. ___, 114 S.Ct. 605 , 126 L.Ed.2d 570 (1993); United States v. Taliaferro, 979 F.2d 1399, 1403 (10th Cir.1992) (congress has the authority to extend a statute of limitations where the original time period has not run); United States v. Knipp, 963 F.2d 839, 844 (6th Cir.1992) (extension of a limitations period before that period has run does not violate the ex post facto clause); United States v. Madia, 955 F.

11
United States v. Valentino R. Madia, Jr., United States of America v. Paul Kampengreen
ca8 · 1992 · cited in 1 Minnesota opinions naming this issue, 1994–1994
2 sentences

1994See, e.g., United States v. Brechtel, 997 F.2d 1108, 1113 (5th Cir.1993) (retroactive extension of the limitations period does not violate the ex post facto clause), cert. denied, - U.S. -, 114 S.Ct. 605 , 126 L.Ed.2d 570 (1993); United States v. Taliaferro, 979 F.2d 1399, 1403 (10th Cir.1992) (congress has the authority to extend a statute of limitations where the original time period has not run); United States v. Knipp, 963 F.2d 839, 844 (6th Cir.1992) (extension of a limitations period before that period has run does not violate the ex post facto clause); United States v. Madia, 955 F.2d 5

1994See, e.g., United States v. Brechtel, 997 F.2d 1108, 1113 (5th Cir.1993) (retroactive extension of the limitations period does not violate the ex post facto clause), cert. denied, ___ U.S. ___, 114 S.Ct. 605 , 126 L.Ed.2d 570 (1993); United States v. Taliaferro, 979 F.2d 1399, 1403 (10th Cir.1992) (congress has the authority to extend a statute of limitations where the original time period has not run); United States v. Knipp, 963 F.2d 839, 844 (6th Cir.1992) (extension of a limitations period before that period has run does not violate the ex post facto clause); United States v. Madia, 955 F.

11
United States v. Barry L. Knipp (91-5312), and Vernon L. Hamilton (91-5452)green
ca6 · 1992 · cited in 1 Minnesota opinions naming this issue, 1994–1994
2 sentences

1994See, e.g., United States v. Brechtel, 997 F.2d 1108, 1113 (5th Cir.1993) (retroactive extension of the limitations period does not violate the ex post facto clause), cert. denied, - U.S. -, 114 S.Ct. 605 , 126 L.Ed.2d 570 (1993); United States v. Taliaferro, 979 F.2d 1399, 1403 (10th Cir.1992) (congress has the authority to extend a statute of limitations where the original time period has not run); United States v. Knipp, 963 F.2d 839, 844 (6th Cir.1992) (extension of a limitations period before that period has run does not violate the ex post facto clause); United States v. Madia, 955 F.2d 5

1994See, e.g., United States v. Brechtel, 997 F.2d 1108, 1113 (5th Cir.1993) (retroactive extension of the limitations period does not violate the ex post facto clause), cert. denied, ___ U.S. ___, 114 S.Ct. 605 , 126 L.Ed.2d 570 (1993); United States v. Taliaferro, 979 F.2d 1399, 1403 (10th Cir.1992) (congress has the authority to extend a statute of limitations where the original time period has not run); United States v. Knipp, 963 F.2d 839, 844 (6th Cir.1992) (extension of a limitations period before that period has run does not violate the ex post facto clause); United States v. Madia, 955 F.

11
United States v. Paul A. Taliaferrogreen
ca10 · 1992 · cited in 1 Minnesota opinions naming this issue, 1994–1994
2 sentences

1994See, e.g., United States v. Brechtel, 997 F.2d 1108, 1113 (5th Cir.1993) (retroactive extension of the limitations period does not violate the ex post facto clause), cert. denied, - U.S. -, 114 S.Ct. 605 , 126 L.Ed.2d 570 (1993); United States v. Taliaferro, 979 F.2d 1399, 1403 (10th Cir.1992) (congress has the authority to extend a statute of limitations where the original time period has not run); United States v. Knipp, 963 F.2d 839, 844 (6th Cir.1992) (extension of a limitations period before that period has run does not violate the ex post facto clause); United States v. Madia, 955 F.2d 5

1994See, e.g., United States v. Brechtel, 997 F.2d 1108, 1113 (5th Cir.1993) (retroactive extension of the limitations period does not violate the ex post facto clause), cert. denied, ___ U.S. ___, 114 S.Ct. 605 , 126 L.Ed.2d 570 (1993); United States v. Taliaferro, 979 F.2d 1399, 1403 (10th Cir.1992) (congress has the authority to extend a statute of limitations where the original time period has not run); United States v. Knipp, 963 F.2d 839, 844 (6th Cir.1992) (extension of a limitations period before that period has run does not violate the ex post facto clause); United States v. Madia, 955 F.

11
United States v. Ronald C. Brechtel and Phillip H. Gattusogreen
ca5 · 1993 · cited in 1 Minnesota opinions naming this issue, 1994–1994
11
Charles Bassil Clements, Jr. v. United Statesgreen
ca9 · 1959 · cited in 1 Minnesota opinions naming this issue, 1994–1994
2 sentences

1994See, e.g., United States v. Brechtel, 997 F.2d 1108, 1113 (5th Cir.1993) (retroactive extension of the limitations period does not violate the ex post facto clause), cert. denied, - U.S. -, 114 S.Ct. 605 , 126 L.Ed.2d 570 (1993); United States v. Taliaferro, 979 F.2d 1399, 1403 (10th Cir.1992) (congress has the authority to extend a statute of limitations where the original time period has not run); United States v. Knipp, 963 F.2d 839, 844 (6th Cir.1992) (extension of a limitations period before that period has run does not violate the ex post facto clause); United States v. Madia, 955 F.2d 5

1994See, e.g., United States v. Brechtel, 997 F.2d 1108, 1113 (5th Cir.1993) (retroactive extension of the limitations period does not violate the ex post facto clause), cert. denied, ___ U.S. ___, 114 S.Ct. 605 , 126 L.Ed.2d 570 (1993); United States v. Taliaferro, 979 F.2d 1399, 1403 (10th Cir.1992) (congress has the authority to extend a statute of limitations where the original time period has not run); United States v. Knipp, 963 F.2d 839, 844 (6th Cir.1992) (extension of a limitations period before that period has run does not violate the ex post facto clause); United States v. Madia, 955 F.

11
State v. Creekpaumgreen
alaska · 1988 · cited in 1 Minnesota opinions naming this issue, 1994–1994
2 sentences

1994See, e.g., United States v. Brechtel, 997 F.2d 1108, 1113 (5th Cir.1993) (retroactive extension of the limitations period does not violate the ex post facto clause), cert. denied, - U.S. -, 114 S.Ct. 605 , 126 L.Ed.2d 570 (1993); United States v. Taliaferro, 979 F.2d 1399, 1403 (10th Cir.1992) (congress has the authority to extend a statute of limitations where the original time period has not run); United States v. Knipp, 963 F.2d 839, 844 (6th Cir.1992) (extension of a limitations period before that period has run does not violate the ex post facto clause); United States v. Madia, 955 F.2d 5

1994See, e.g., United States v. Brechtel, 997 F.2d 1108, 1113 (5th Cir.1993) (retroactive extension of the limitations period does not violate the ex post facto clause), cert. denied, ___ U.S. ___, 114 S.Ct. 605 , 126 L.Ed.2d 570 (1993); United States v. Taliaferro, 979 F.2d 1399, 1403 (10th Cir.1992) (congress has the authority to extend a statute of limitations where the original time period has not run); United States v. Knipp, 963 F.2d 839, 844 (6th Cir.1992) (extension of a limitations period before that period has run does not violate the ex post facto clause); United States v. Madia, 955 F.

11
State v. Johnsongreen
vt · 1992 · cited in 1 Minnesota opinions naming this issue, 1994–1994
2 sentences

1994See, e.g., United States v. Brechtel, 997 F.2d 1108, 1113 (5th Cir.1993) (retroactive extension of the limitations period does not violate the ex post facto clause), cert. denied, - U.S. -, 114 S.Ct. 605 , 126 L.Ed.2d 570 (1993); United States v. Taliaferro, 979 F.2d 1399, 1403 (10th Cir.1992) (congress has the authority to extend a statute of limitations where the original time period has not run); United States v. Knipp, 963 F.2d 839, 844 (6th Cir.1992) (extension of a limitations period before that period has run does not violate the ex post facto clause); United States v. Madia, 955 F.2d 5

1994See, e.g., United States v. Brechtel, 997 F.2d 1108, 1113 (5th Cir.1993) (retroactive extension of the limitations period does not violate the ex post facto clause), cert. denied, - U.S. -, 114 S.Ct. 605 , 126 L.Ed.2d 570 (1993); United States v. Taliaferro, 979 F.2d 1399, 1403 (10th Cir.1992) (congress has the authority to extend a statute of limitations where the original time period has not run); United States v. Knipp, 963 F.2d 839, 844 (6th Cir.1992) (extension of a limitations period before that period has run does not violate the ex post facto clause); United States v. Madia, 955 F.2d 5

11
Commonwealth v. Bargerongreen
mass · 1988 · cited in 1 Minnesota opinions naming this issue, 1994–1994
2 sentences

1994See, e.g., United States v. Brechtel, 997 F.2d 1108, 1113 (5th Cir.1993) (retroactive extension of the limitations period does not violate the ex post facto clause), cert. denied, - U.S. -, 114 S.Ct. 605 , 126 L.Ed.2d 570 (1993); United States v. Taliaferro, 979 F.2d 1399, 1403 (10th Cir.1992) (congress has the authority to extend a statute of limitations where the original time period has not run); United States v. Knipp, 963 F.2d 839, 844 (6th Cir.1992) (extension of a limitations period before that period has run does not violate the ex post facto clause); United States v. Madia, 955 F.2d 5

1994See, e.g., United States v. Brechtel, 997 F.2d 1108, 1113 (5th Cir.1993) (retroactive extension of the limitations period does not violate the ex post facto clause), cert. denied, - U.S. -, 114 S.Ct. 605 , 126 L.Ed.2d 570 (1993); United States v. Taliaferro, 979 F.2d 1399, 1403 (10th Cir.1992) (congress has the authority to extend a statute of limitations where the original time period has not run); United States v. Knipp, 963 F.2d 839, 844 (6th Cir.1992) (extension of a limitations period before that period has run does not violate the ex post facto clause); United States v. Madia, 955 F.2d 5

11
United States v. Eric Alan Wayne, United States of America v. Eric Alan Waynegreen
ca8 · 1990 · cited in 1 Minnesota opinions naming this issue, 1991–1991
11

Distinguished, questioned or overruled (1)

CaseNegativeCited
Haas v. Hathawayred
orctapp · 1996 · cited in 1 Minnesota opinions naming this issue, 2004–2004
2 sentences

2004See Weaver, 450 U.S. at 28-29 , 101 S.Ct. at 964 ; see also State v. Garcia, 670 N.W.2d 297, 299 (Minn.App.2003) (holding that the 2000 amendment did not violate the ex post facto clause because “[wjhen enacted, the [2000] amendment merely exposed appellant to possible additional punishment in the event of a future probation violation”), review granted (Minn. Dec. 23, 2003); Gasper v. Gunter, 851 P.2d 912, 918 (Co.1993) (holding that application of a statute prohibiting credit for time on parole did not implicate ex post facto prohibition because the forfeiture of jail credit was based on “an

2004See Weaver, 450 U.S. at 28-29 , 101 S.Ct. at 964 ; see also State v. Garcia, 670 N.W.2d 297, 299 (Minn.App.2003) (holding that the 2000 amendment did not violate the ex post facto clause because “[wjhen enacted, the [2000] amendment merely exposed appellant to possible additional punishment in the event of a future probation violation”), review granted (Minn. Dec. 23, 2003); Gasper v. Gunter, 851 P.2d 912, 918 (Co.1993) (holding that application of a statute prohibiting credit for time on parole did not implicate ex post facto prohibition because the forfeiture of jail credit was based on “an

11

Also cited on this issue (5)

CaseCitedYears
Joel Armen Underwood, III. v. State of Minnesota neutral
minnctapp · 2024
1 sentence

2025Underwood, 8 N.W.3d at 661 .

12025–2025
State v. Ryan green
· 1868
1 sentence

2016Raw v. Bergstrom, 845 N.W.2d 764, 794 (Minn.2014) (quoting State v. Ryan, 13 Minn. 370, 375-76 , 13 Gil. 343 , 348 (1868)).

12016–2016
State v. Burns green
minnctapp · 1994
1 sentence

1999An ex post facto violation does not occur “if the change effected is merely procedural and does not increase the punishment, change the elements of the offense, or change the ultimate facts necessary to establish guilt.” Burns, 524 N.W.2d at 520 (citing United States ex. rel.

11999–1999
State v. Howard green
minnctapp · 1985
11993–1993
State v. Willis green
minn · 1983
11993–1993

Statutes the citing opinions construe

MN § Minn. Stat. § 609.342 (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

CA 372 (1958–2025) PA 355 (1950–2026) FL 245 (1982–2026) OH 219 (1993–2024) TX 166 (1971–2026) IL 135 (1974–2025) WA 112 (1989–2024) IN 107 (1974–2026) CT 91 (1981–2025) LA 70 (1978–2025) MO 61 (1988–2024) NY 61 (1939–2023) OR 60 (1980–2026) MS 58 (1976–2023) NJ 56 (1978–2026) TN 54 (1993–2025) KS 50 (1987–2026) MI 46 (1942–2026) SC 46 (1989–2023) AZ 43 (1976–2025) NC 42 (1980–2020) IA 40 (1979–2025) KY 29 (1983–2024) AR 29 (1987–2026) MA 29 (1980–2025) WV 27 (1980–2025) WI 27 (1994–2023) RI 26 (1917–2022) MD 25 (1980–2023) DE 23 (1985–2023) OK 23 (1980–2025) CO 22 (1990–2025) GA 22 (1972–2018) AL 21 (1981–2025) AK 21 (1986–2026) MT 20 (1979–2026) NE 17 (1983–2026) VT 17 (2008–2024) ID 17 (1979–2022) DC 17 (1972–2023) NV 16 (1977–2018) MN 15 (1985–2026) HI 15 (1994–2025) VA 14 (1984–2025) ME 14 (1984–2026) SD 11 (1993–2022) ND 10 (1980–2010) UT 10 (1983–2024) NM 9 (2004–2016) WY 7 (1895–2021) NH 6 (1974–2008) PR 4 (1949–1961)

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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