proportionality analysis (Minnesota) · Go Syfert
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proportionality analysis in Minnesota

7 Minnesota opinions name it 2 courts 2001–2018 0 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 (5)

CaseFollowedCited
Daniel W. Varel v. Banc One Capital Partners, Inc., Formerly Known as Mventure Corp.green
ca5 · 1995 · cited in 1 Minnesota opinions naming this issue, 2018–2018
1 sentence

2018See Restatement (Second) of Contracts § 229, cmts. b-c (explaining that the rule applies "only where occurrence of the condition was not a material part of the agreed exchange" and requires weighing to determine "whether the forfeiture is 'disproportionate' "); see also Varel v. Banc One Capital Partners, Inc. , 55 F.3d 1016 , 1018 (5th Cir. 1995) (discussing how courts applying the Restatement must examine "whether performing the condition precedent was the object of the contract or merely incidental to it" and then weigh whether the penalty is extreme when "measured against the purpose" of t

11
State v. Craiggreen
minn · 2013 · cited in 1 Minnesota opinions naming this issue, 2017–2017
1 sentence

2017See, e.g., State v. Craig, 826 N.W.2d 789, 793 (Minn. 2013).

11
State of Minnesota v. Kenneth E. Andersengreen
minn · 2015 · cited in 1 Minnesota opinions naming this issue, 2016–2016
1 sentence

2016See State v. Andersen, 871 N.W.2d 910, 915 (Minn. 2015) (“An assignment of error based on mere assertion and not supported by any argument or authorities in appellant’s brief is waived and will not be considered on appeal unless prejudicial error is obvious on mere inspection.” (quotation omitted)).

11
Commonwealth v. Mitchellgreen
pacommwct · 2003 · cited in 1 Minnesota opinions naming this issue, 2016–2016
1 sentence

2016Regarding the particular characteristics of the crime, courts consider the actual harm risked and caused by the conduct, as well as any mitigating or aggravating circumstances, such as the defendant’s motive and criminal history.”); Commonwealth v. Mitchell, 833 A.2d 1220, 1223 (Pa. Commw.

11
Baker v. Ploetzgreen
minn · 2000 · cited in 1 Minnesota opinions naming this issue, 2003–2003
1 sentence

2003See Minn.Stat. 645.17 (2002) (the legislature does not intend a result that is impossible, to execute); Baker v. Ploetz, 616 N.W.2d 263, 269 (Minn.2000) (noting that *916 various provisions of the same statute must be interpreted in light of each other).

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
State v. Rewitzer green
minn · 2000
1 sentence

2016Id.

12016–2016
Borgen v. 418 Eglon Avenue green
minnctapp · 2006
1 sentence

2016Cf. Borgen, 712 N.W.2d at 813–14 (stating that second factor involves “analyz[ing] the severity level of the offense and look[ing] at the penalties for other offenses at that level” and stressing that “no court, including the United States Supreme Court, has analyzed this prong by looking at actual imposition of fines, but rather by considering what fines are permissive or allowable” (emphasis added)).

12016–2016
Container Corp. of America v. Franchise Tax Board green
scotus · 1983
2 sentences

2003The proportionality test has two prongs, “internal consistency” and “external consistency.” See Container Corp., 463 U.S. at 169-70 , 103 S.Ct. 2933 .

2003The proportionality test has two prongs, “internal consistency” and “external consistency.” See Container Corp., 463 U.S. at 169-70 , 103 S.Ct. 2933 .

12003–2003
Solem v. Helm red
scotus · 1983
2 sentences

2001Neither Rewitzer nor Bajakajian came up with a “bright line,” but did come up with a proportionality test, set out in Solem v. Helm, 463 U.S. 277, 288 , 103 S.Ct. 3001 , 77 L.Ed.2d 637 (1983).

2001Neither Rewitzer nor Bajakajian came up with a “bright line,” but did come up with a proportionality test, set out in Solem v. Helm, 463 U.S. 277, 288 , 103 S.Ct. 3001 , 77 L.Ed.2d 637 (1983).

12001–2001

Where else courts name it

TX 270 (1980–2026) MI 189 (1986–2026) WV 149 (1980–2026) CA 138 (1983–2026) IL 111 (1983–2026) MS 106 (1984–2026) OH 79 (1986–2026) OR 67 (1980–2026) FL 66 (1993–2025) TN 62 (1986–2022) PA 38 (1992–2026) WA 37 (1980–2026) CO 36 (1981–2026) ID 33 (1982–2023) AZ 33 (1982–2026) IN 32 (1984–2020) AL 28 (1982–2024) SD 23 (1985–2024) MD 21 (1985–2026) KS 17 (1986–2020) IA 17 (1984–2023) UT 16 (1996–2024) DE 15 (1988–2025) WY 14 (1983–2026) MA 13 (1979–2024) MO 12 (1985–2018) VA 11 (1979–2023) NJ 10 (1995–2023) GA 10 (1994–2023) WI 9 (1988–2022) LA 9 (1983–2017) ME 8 (1991–2025) NC 8 (1985–2023) MN 7 (2001–2018) NE 6 (1991–2022) NM 5 (1988–2019) ND 4 (1997–2025) DC 4 (1993–2007) RI 4 (2004–2013) NH 4 (1977–2013) OK 4 (1994–2006) AK 3 (2022–2025) NV 3 (1991–2020) KY 3 (2004–2020) NY 3 (1994–2005) CT 3 (2016–2025) SC 2 (2000–2013) VT 2 (1995–2018)

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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