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Cited by

Opinions in Minnesota that cite Martinek v. State, 678 N.W.2d 714.

21 citing documents.

  • State of Minnesota, Appellant, Minn. Ct. App. 2026
    “Once a sentence has expired, the court no longer has jurisdiction to modify even what may be an unauthorized sentence.” (citing Purdy, d at 498-99).
  • Fidel Pizarro-Rios v. State of Minnesota Minn. Ct. App. 2025
  • Fidel Pizarro-Rios v. State of Minnesota Minn. Ct. App. 2025
    9 Pizarro-Rios contended that his sentence expired when the district court filed the February 15, 2018 sentencing order and that, d 714 (Minn. App. 2004), 10 the court lacked subject-matter jurisdiction to modify his sentence afterward.
  • Paul Casey Mason, Appellant, Minn. Ct. App. 2025
    -65 (Minn. App. 2011) (dismissing appeal because sentence expired and concluding that this court, like the district court, lacked jurisdiction 7 to “modify the sentence to impose further sanctions”); -19 (Minn. App. 2004) (concluding that district court lacked jurisdiction to enforce the terms of conditional release when it had not altered the sentence to include conditional release before sentence expired); -99 (Minn. App. 1999) (“The expiration of a sentence operates as
  • State of Minnesota, Respondent, Minn. Ct. App. 2024
    In light of that expiration, both this court and the district court lack the authority “to modify even what may be an unauthorized sentence.” -65 (Minn. App. 2011) ().
  • State of Minnesota, Respondent, Minn. Ct. App. 2021
    But as Christianson poin ts out, “[o]nce a sentence has expired, the court no longer has jurisdiction to modify even what may be an unauthorized sentence.” Martinek v. State , (-99 (Minn. App. 1999))
  • State of Minnesota, Respondent, Minn. Ct. App. 2020
  • State v. Franson 921 N.W.2d 783 Minn. Ct. App. 2018
  • State v. Franson 921 N.W.2d 783 Minn. Ct. App. 2018
    Franson argues that Purdy , , and Martinek v. State , are controlling here and contends that when the district court vacated the conditional-release term, the district court automatically lost jurisdiction to correct his sentence.
  • State of Minnesota, Respondent, Minn. Ct. App. 2018
    Thereafter, “the court no longer has jurisdiction to mo dify even what may be an unauthorized sentence.”
  • State of Minnesota, Respondent, Minn. Ct. App. 2018
    “Once a sentence has expired, the court no longer has jurisdiction to modify even what may be an unauthorized sentence.” (citing Purdy, d at 498-99).
  • State of Minnesota v. Shawn Theodore Hoshal Minn. Ct. App. 2016
  • State of Minnesota v. Shawn Theodore Hoshal Minn. Ct. App. 2016
    But an unauthorized sentence may be modified when a defendant “has notice that a correction is required and has not developed a crystallized expectation as to the finality of the sentence.” d 714, 718 (Minn. App. 2004).
  • Robel Belay Kubrom v. State of Minnesota 863 N.W.2d 88 Minn. Ct. App. 2015
  • Robel Belay Kubrom v. State of Minnesota 863 N.W.2d 88 Minn. Ct. App. 2015
  • State of Minnesota v. Jack Perry Frazier Minn. Ct. App. 2014
  • State of Minnesota v. Jack Perry Frazier Minn. Ct. App. 2014
  • State v. Henry 809 N.W.2d 251 Minn. Ct. App. 2012
  • State v. Henry 809 N.W.2d 251 Minn. Ct. App. 2012
    1 (holding that judge's letter to department of corrections could not be construed as an order amending defendant's sentence, partly because "[an exchange of letters, to which a defendant is not privy and which is not made a part of the official record, deprives a defendant of a fundamental right of
  • State v. Hannam 792 N.W.2d 862 Minn. Ct. App. 2011
  • State v. Hannam 792 N.W.2d 862 Minn. Ct. App. 2011
    respondent argues that his sentence may no longer be modified because it has expired.