Cited by

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

22 citing documents.

State of Minnesota v. Melvin Junior Mitchell Minn. Ct. App. 2026
865 (Minn. App. 2011) (dismissing the state’s appeal from amended sentencing order when Hannam’s sentence expired before the state filed the appeal, concluding this court, like the district court, does not have “authority to amend or modify the sentence to impose further sanctions” after the sentence expired) ; -19 (Minn. App. 2004) (concluding district court lacked authority to add conditional-release term after sentence expired); (“The expiration of a sentence operates as a discharge that bars
State of Minnesota v. Devin Dion Tillman 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 v. State of Minnesota 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 v. Clyde Harry Barr, III 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 v. Shannon Lee Christianson, Jr. 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 v. Jeremy Shane Zimmermann 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 v. Shawn Troy Carlson Minn. Ct. App. 2018
Thereafter, “the court no longer has jurisdiction to mo dify even what may be an unauthorized sentence.”
State of Minnesota v. Steven Roger Jones 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.