Minnesota Statutes

Minn. Stat. § 80A.22 (2026)

[Repealed]

✓ current as of May 2026

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[Repealed, 2006 c 196 art 1 s 51,52]

Notes of Decisions

Cited in 4 cases, 1980–2001 · leading case: State v. Eaton, 292 N.W.2d 260 (Minn. 1980).

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State v. Eaton, 292 N.W.2d 260 (Minn. 1980). · cites it 2× “Minn.Stat. § 80A.22, subd. 3 (1978). This subdivision clearly expresses the legislative intent to allow a prosecution for theft by swindle even though the state also prosecutes for securities fraud.”

State v. Stith, 292 N.W.2d 269 (Minn. 1980). · cites it 4× “Minn.Stat. § 80A.22, subd. 3 (1978). Stith goes on to argue, however, that the seven counts of securities fraud are multiplicious.”

State v. Williams, 396 N.W.2d 840 (Minn. Ct. App. 1986). · cites it 4× “The Eaton court rejected this argument and noted that while “inferred” legislative intent was dispositive in Kalvig , the securities fraud statute, Minn.Stat. § 80A.22, subd. 3 (1978), manifests a clear legislative intent to allow prosecution for theft by swindle in addition to…”

State v. Craven, 628 N.W.2d 632 (Minn. Ct. App. 2001). · cites it 2× “at 268 (quoting Minn.Stat. § 80A.22, subd. 3 (1978)). The fleeing causing death statute contains a proviso that indicates that the statute only applies where the death does not constitute murder or manslaughter.”

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