Cited by
Opinions in Minnesota that cite State v. Skipintheday, 717 N.W.2d 423.
- State of Minnesota v. Latalia Anjolie Margalli Minn. Ct. App. 2026
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Ryan Timothy Kellen v. State of Minnesota
Minn. Ct. App. 2026
But multiple sentences may not be imposed if they “unfairly exaggerate the criminality of the defendant’s conduct.”
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State of Minnesota v. Anthony Leandre Winston
Minn. Ct. App. 2026
“Whether a defendant commits multiple- victim crimes is a question of law, which this court reviews de novo.” (citation omitted).
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State of Minnesota v. Timothy Michael Leistiko
Minn. Ct. App. 2026
conduct is considered when multiple sentences arise out of a single behavioral incident, this does not mean such unfair exaggeration cannot also be considered in another context.
- State of Minnesota v. Jonathan Evan Smallman Minn. Ct. App. 2025
- Milton K. Sanders, Appellant, vs. State of Minnesota, Respondent Minn. 2025
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Milton K. Sanders, Appellant, vs. State of Minnesota, Respondent
Minn. 2025
Under the multiple-victim exception to section 609.035, a district court may impose “multiple sentences for multiple crimes arising out of a single behavioral incident if: (1) the crimes affect multiple victims; and (2) multiple sentences do not unfairly exaggerate the criminality of the defendant’s conduct.” d 423, 426 (Minn. 2006).
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State of Minnesota v. Travis Clay Andersen
Minn. Ct. App. 2025
If there are multiple victims, the district court must not impose sentences that “unfairly 10 exaggerate the criminality of the defendant’s conduct.” d 423, 426 (Minn. 2006).
- State of Minnesota v. Henry Albert Allison, Jr. Minn. 2024
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State of Minnesota v. Henry Albert Allison, Jr.
Minn. 2024
[and l]ocal residents may fear for their safety,”
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Tyler Douglas Flantz v. State of Minnesota
Minn. Ct. App. 2022
(permitting multiple sentences when the crimes involve multiple victims and the sentences do not unfairly exaggera te the criminality of the 1 Flantz also argues that his conviction for count five violated the Double Jeopardy Clauses of the Minnesota and U.S. Constitutions.
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State of Minnesota v. Christopher Allen Hitchcock
Minn. Ct. App. 2022
Under the multiple-victim rule, “courts are not prevented from giving a defendant multiple sentences for multiple crimes arising out of a single behavioral incident if: (1) the crimes affect multiple victims; and (2) multiple sentences do not unfairly exaggerate the criminality of the defendant’s conduct.”
- State of Minnesota v. Jesse Nikolas Rowland Minn. Ct. App. 2021
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Jalisa Yvette Crosby v. State of Minnesota
Minn. Ct. App. 2021
-80 (Minn. App. 2005), aff’d
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Minn. 2021
We recognized the unique nature of this offense in State v. Skipintheday, when we said, “a coconspirator helps someone commit a crime, but an accomplice after - the-fact helps a person who has committed a crime evade the law.”
- State of Minnesota v. Jonathon Ross Rudquist Minn. Ct. App. 2021
- Victor Demetrius Cole v. State of Minnesota Minn. Ct. App. 2021
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State of Minnesota v. William Arnold Lindeman
Minn. Ct. App. 2021
“Whether a defendant commits multiple-victim crimes is a question of law, which this court reviews de novo.” State v. Skipintheday
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State of Minnesota v. Paul Andrew Youngstedt
Minn. Ct. App. 2020
to mention an important judicially-created exception under which courts may impose multiple sentences for “crimes aris ing out of a single be havioral incident if: (1) the crimes affect multiple victims; and (2) multiple sentences do not unfairly exaggerate the criminality of the defendant’s conduct.” See State v. Ferguson , (quoting State v. Skipintheday , ).
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State of Minnesota v. Angel Torrejon Ramirez
Minn. Ct. App. 2020
“[C]ourts are not prevented from giving a defendant multip le sentences for multiple crimes arising out of a sin gle behavioral incident if: (1) the crimes affect multiple victims; and (2) multiple sentences do not unfairly exaggerate the criminality of the defendant ’s conduct.” State v. Skipintheday , ().
- State of Minnesota v. Xavier Alfred Haywood Minn. Ct. App. 2020
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Minn. 2020
This rule allows “multiple sentences for multiple crimes arising out of a single behavioral incident if: (1) the crimes affect multiple victims; and (2) multiple sentences do not unfairly exaggerate the criminality of the defend ant’s conduct.” State v. Skipintheday , .
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State of Minnesota,
Minn. 2020
We review de novo “[w]hether an offense is subject to multiple sentences under Minn. Stat. § 609.035.” State v. Ferguson , 90 (Minn. 2012) (citing State v. Skipintheday , ).
- State of Minnesota v. Michael Steel Minn. Ct. App. 2019
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State of Minnesota v. Jason David Kohlwey
Minn. Ct. App. 2019
d 423, 426 (Minn. 2006).
- State v. Branch 930 N.W.2d 455 Minn. Ct. App. 2019
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State v. Branch
930 N.W.2d 455
Minn. Ct. App. 2019
State v. Skipintheday , , 426 (Minn. 2006) ; see also Munt , d at 417 (stating that legislature did not intend to immunize offenders from consequences of *458 separate crimes against separate victims.
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State of Minnesota v. Lance Martin Odegard
Minn. Ct. App. 2018
Imposition of two sentences “[C]ourts are not prevented from giving a defendant multiple sentences for multiple crimes arising out of a single behavioral incident if: (1) the crimes affect multiple victims; and (2) multiple sentences do not unfairly exaggerate the criminality of the defendant 's conduct.”
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State of Minnesota v. Shane Lester Gullickson
Minn. Ct. App. 2018
a court may only enter a sentence for one crime arising out of a single behavioral incident, “courts are not prevented from giving a defendant multiple sentences for multiple crimes arising out of a single behavioral incident if: (1) the crimes affect multiple victims; and (2) multiple sentences do not unfairly exaggerate the criminality of the defendant ’s conduct.” State v. Skipintheday , , 426 (M inn.
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State of Minnesota v. Robert John Lund
Minn. Ct. App. 2018
“[C]ourts are not prevented from giving a defendant multiple sentences for multipl e crimes arising out of a single behavioral incident if: (1) the cr imes affect multiple victims; and (2) multiple 10 sentences do not unfairly exaggerate the criminality of the defendant’s conduct.”
- Demiteras Al Cooper v. State of Minnesota Minn. Ct. App. 2018
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State of Minnesota v. Sandra Grazzini-Rucki
Minn. Ct. App. 2017
However, under the multiple-victim exception, “courts are not prevented from giving a defendant multiple sentences for multiple crimes arising out of a single behavioral incident if: (1) the crimes affect multiple victims; and (2) mu ltiple sentences do not unfairly exaggerate the criminality of the defendant’s conduct.”
- State v. Ivy 902 N.W.2d 652 Minn. Ct. App. 2017
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State v. Ivy
902 N.W.2d 652
Minn. Ct. App. 2017
(stating that under-the multiple-victim exception, "courts are not prevented from giving a defendant multiple sentences for multiple crimes arising out of a single behavioral incident if: (1) the crimes affect multiple victims; and (2) multiple sentences do not unfairly exaggerate the criminality'of
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State of Minnesota v. Christian David-Robert Wille
Minn. Ct. App. 2017
A district court may impose “multiple sentences for multiple crimes arising out of a single behavioral incident if: (1) the crimes affect multiple victims; and (2) multiple sentences do not unfairly exaggerate the criminality of the defendant’s conduct.”
- State of Minnesota v. Tylynne Lashawn Wilson Minn. Ct. App. 2016
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State of Minnesota v. Tylynne Lashawn Wilson
Minn. Ct. App. 2016
See, e.g., Kenard, d at 444-45 (discussing caselaw assigning severity level rankings of 8 to 10 for accomplice after the fact crimes); aff’d, (ruling district court did not abuse discretion by assigning severity level 8 to accomplice after the fact crime).
- State of Minnesota v. Adaiah Deontraie Townsend 872 N.W.2d 758 Minn. Ct. App. 2015
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State of Minnesota v. Adaiah Deontraie Townsend
872 N.W.2d 758
Minn. Ct. App. 2015
This offense is distinguished from those in which a person aids and abets the commission of a crime or conspires with another to commit a crime; a person who aids an offender after the fact “‘interfere[es] with the processes of justice and is best dealt with in those terms.’” (quoting 2 Wayne R. LaFave, Substantive Criminal Law § 13.6(a), at 404 (2d ed. 2003)).
- State of Minnesota v. Peter William Warren Minn. Ct. App. 2015
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State of Minnesota v. Peter William Warren
Minn. Ct. App. 2015
Under the multiple-victim exception, a district court may impose “multiple sentences for multiple crimes arising out of a single behavioral incident if: (1) the crimes affect multiple victims; and (2) multiple sentences do not unfairly exaggerate the criminality of the defendant’s conduct.”
- State of Minnesota v. Fonati McArthur Diggs Minn. Ct. App. 2015
- State of Minnesota v. Fonati McArthur Diggs Minn. Ct. App. 2015
- Tommie Relando Norwood v. State of Minnesota Minn. Ct. App. 2014
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Tommie Relando Norwood v. State of Minnesota
Minn. Ct. App. 2014
See Minn. Stat. § 609.035 (2012); d 423, 426 (Minn. 2006).
- State of Minnesota v. La’Rog Daquan Meadows Minn. Ct. App. 2014
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State of Minnesota v. La’Rog Daquan Meadows
Minn. Ct. App. 2014
“[H]is offense is instead that of interfering with the processes of justice,” (quotation omitted); see, e.g., Scruggs, d at 641 (“[L]ying to the police is after-the-fact assistance, which is not relevant to an accomplice determination.” (quotation omitted)).
- State v. Amundson 828 N.W.2d 747 Minn. Ct. App. 2013
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State v. Amundson
828 N.W.2d 747
Minn. Ct. App. 2013
-27 , 426 n. 3 (Minn.2006) (distinguishing between co-conspirator who helps someone commit crime and accomplice-after-the-fact who is involved after victims have been harmed).
- Wallace v. State 820 N.W.2d 843 Minn. 2012