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State v. Shattuck

Supreme Court of Minnesota
Dec 16, 2004
689 N.W.2d 785 (Minn. 2004)

Summary

applying Apprendi and Blakely to hold that the district court's imposition of an upward durational departure sentence violated appellant's Sixth Amendment right to trial by jury

Summary of this case from State v. Ali

Opinion

No. C6-03-362.

December 16, 2004.


ORDER


This case was heard on the court's oral calendar on November 30, 2004. The court has decided the substantive issue but desires briefing on four specific questions relating to remedy.

Based upon all the files, records and proceedings herein,

It is the determination of this court that, in accordance with the rule of Blakely v. Washington, ___ U.S. ___, 124 S.Ct. 2531, 159 L.Ed.2d 403 (2004), the district court's imposition of an upward durational departure under Minn.Stat. § 609.109, subd. 4 (2002), from the Minnesota Sentencing Guidelines' presumptive sentence violated appellant's Sixth Amendment right to trial by jury. We note that because imposition of the presumptive sentence is mandatory absent additional judicial findings under the legislatively-created Guidelines regime, the presumptive sentence is the maximum penalty authorized solely by the jury's verdict for the purposes of Apprendi v. New Jersey, 530 U.S. 466, 120 S.Ct. 2348, 147 L.Ed.2d 435 (2000). The test of Apprendi is one of functional effect rather than form. Id. at 494, 120 S.Ct. 2348. Because the Guidelines regime permits the district court to durationally depart upward from a presumptive sentence after finding aggravating factors not considered by the jury, it unconstitutionally usurps the role and undermines the function of the jury. A full opinion will follow.

IT IS HEREBY ORDERED that the parties shall, within 30 days of this order, file and serve supplemental briefs on the issue of remedy. Without foreclosing the possibility of imposing the presumptive sentence, at a minimum the briefs shall address the following questions:

(1) Whether the portions of the Sentencing Guidelines that unconstitutionally allow the district court to impose an upward durational departure based on facts not reflected in the jury's verdict or admitted by the defendant are severable from the remainder of the Guidelines. See Minn.Stat. § 645.20 (2002); City of Duluth v. Sarette, 283 N.W.2d 533, 537 (Minn. 1979).

(2) If the unconstitutional portions of the Guidelines properly may be severed, whether this court has the inherent authority to authorize the use of sentencing juries and a bifurcated trial process.

(3) Whether a sentencing jury or a bifurcated trial process implicates double jeopardy concerns.

(4) In the present case, what specific remedy is appropriate? In particular, does the fact that the district court denied appellant's request to place before the jury aggravating factors that would, if found, justify sentencing enhancement, affect the disposition of this matter?


I respectfully dissent. Supplemental briefing is neither necessary nor appropriate. "The presumptive sentence is the maximum penalty authorized solely by the jury's verdict." Under the sentencing guidelines, "imposition of the presumptive sentence is mandatory absent additional judicial findings." Because the judicial findings made here were void ab initio and of no legal effect, I would remand to the district court for imposition of the presumptive sentence. See generally State v. Geller, 665 N.W.2d 514, 517 (Minn. 2003), Williams v. State, 361 N.W.2d 840, 843-44 (Minn. 1985). Any responsibility for fixing the " Blakely problem" lies with the legislature and not this court.


Summaries of

State v. Shattuck

Supreme Court of Minnesota
Dec 16, 2004
689 N.W.2d 785 (Minn. 2004)

applying Apprendi and Blakely to hold that the district court's imposition of an upward durational departure sentence violated appellant's Sixth Amendment right to trial by jury

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applying Blakely in Minnesota

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applying Blakely in Minnesota

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ordering additional briefing on appropriate remedy

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ordering additional briefing on appropriate remedy

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In Shattuck, the court reversed the imposition of an upward durational departure under the repeat sex-offender statute, Minn. Stat. § 609.109, subd.

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invalidating upward durational departure under repeat sex-offender statute because departure was based on judicially determined aggravating factors not admitted by defendant or considered by jury

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In Shattuck, the supreme court held that the imposition of an upward durational departure based on aggravating factors not considered by a jury was a violation of the defendant's rights as articulated in Blakely.

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ordering supplemental briefing on the appropriate remedy

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ordering additional briefing on appropriate remedy

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ordering supplemental briefing on the issue of the appropriate remedy

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applying Blakely v. Washington, 124 S. Ct. 2531 to the Minnesota Sentencing Guidelines

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Case details for

State v. Shattuck

Case Details

Full title:STATE of Minnesota, Respondent, v. Robert Allen SHATTUCK, Appellant

Court:Supreme Court of Minnesota

Date published: Dec 16, 2004

Citations

689 N.W.2d 785 (Minn. 2004)

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