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According to Quarles, to increase Quarles’s criminal-history score before sentencing the next offense.

A trial error is an error that “occurred 3 (allowing courts, when sentencing a defendant on the same day for multiple separate offenses, to impose the sentences in chronological order and to use each conviction to incrementally increase the criminal- history score for the next offense to be sentenced); Minn. Sent’g Guidelines 2B.1.e (2023) (enc

Minn. Sent’g Guidelines 1.B.10, 2.B.1.e (2022)

“Hernandizing” each count and sentencing 2 Gilfillan to serve concurrent terms of 24, 36, 60, 78, and 102 months, followed by five years of conditional release.

(employing the process in determining the defendant’s criminal history).

Under the Hernandez method of sentencing, if “a defendant is sentenced for multiple offenses on the same day, a conviction for which the defendant is first sentenced is added to his or her criminal-history score for another offense for which he or she is also sentenced.” (allowing a district court to increase a defendant’s criminal-history score when sentencing multiple offenses on the same day if certain conditions are met).

(allowing the district court to sentence separate and distinct convictions sequentially); see also Minn. Sent’g Guidelines 2.B.1.e (2018 & Supp. 2019) (same).

We agree that correcting a 1 (allowing the district court to sentence separate and distinct convictions sequentially).

Guidelines, 1.B.(9) (2014); - 81 (Minn. 1981).

Guidelines 2.B.1 (Supp. 2019) (stating that the sentencing court is to assign a “particular weight” for each felony conviction “provided that a felony sentence was stayed or imposed before the current sentencing”); 481 (Minn. 1981) (concluding, in a case in which the defendant was sentenced on the same day for three separate and distinct offenses, that the district court could consider the first two convictions in determining the defendant’s criminal-history score for the third conviction); d 4

Burdunice next argues unconvincingly that the district court’s violates statutory and constitutional law.

2.B.107 (2018); -81 (Minn. 1981).

Saari argue s that one of the sentences must be vacated and, because the district court Hernandized2 the sentences, “a 2 Minn. Sent.

See State v. Hernandez , (Minn .

Guidelines 1.B.(10) (2018); -81 (Minn. 1981).

Guidelines 1.B.(10) (2018); -81 (Minn. 1981).

See S tate v. 9 Hernandez, -81 (Minn. 1981).

See State v. Longo , -04 (Minn. App. 2018); see also State v. Hernandez , d 478, 481 (Minn. 1981) (permitting district court to apply increased criminal -history score for the last of several serial convictions that were not part of “a single behavioral incident or course of conduct”).

After application of the rules for determining crim inal history, -81 (Minn. 1981) (stating that, when multi ple offenses are sentenced by the same court on the same day, the offense fo r which the defendant is first sentenced is included in the criminal history of the next offense sentenced), the longest presumptive range of sentence for Schuessler’s convictions was 51 to 70

When doing so, the district court utilized State v. Hernandez

Because we affirm 3 Pursuant to State v. Hernandez , when a defendant is sentenced for multiple convictions on the same day for separate offenses not part of a single behavioral incident, it is pr oper for the district court to include an earlier-sentenced conviction when calculating the appropriate criminal-history score for a later-sentenced convict

Guidelines 2.B.1.e (Supp. 2015); See State v. Hernandez , -81 (Minn. 1981) (providing that a district court, when sentencing multiple fel ony offenses at the same time, should include earlier-sentenced offenses in calculating a criminal-history score for each subsequent offense).

(d 478, 479 (Minn. 1981) , to hold that, when sentencing a defendant on the same day for multiple offenses not part of a single behavioral incident, occurring at different times, and involving different victims, a district court may assign one criminal history point for each previous felony conviction); see also State v.

–81 (Minn. 1981); see also Minn. Sent.