Cited by

Opinions in Minnesota that cite State v. Chauvin, 723 N.W.2d 20.

55 citing documents.

State of Minnesota, Respondent, Minn. Ct. App. 2026
Reimer, d at 199; (“Blakely errors are not structural and thus are subject to a harmless error analysis,” meaning that a reviewing court determines whether the error is harmless beyond a reasonable doubt).
In re State of Minnesota, Petitioner, Minn. 2023
We have acknowledged that “a court has inherent judicial authority to engage in activities that are (1 ) necessary (2) to achieve a unique judicial function (3) without infringing on equally important legislative or executive functions.”
Minn. 2022
This inherent judicial power has been used in a variety of contexts, including sentencing.9 d 20, 25 –27 (Minn. 2006), we held that to ensure that the offender’s sentence was not unconstitutional under Blakely v. Washington, 542 U.S. 296, 303 (2004), the district court had the inherent judicial power to impanel a sentencing jury.
State of Minnesota, Respondent, Minn. Ct. App. 2022
(applying harmless -error test to Blakely violation).
In re the Marriage of: Benjamin Thomas Miller, petitioner, Respondent, Minn. Ct. App. 2022
A district court’s inherent judicial authority empowers it to take actions that are: “(1) necessary (2) to achieve a unique judicial function (3) without infringing on equally important legislative or executive functions.”
State of Minnesota, Minn. 2021
See Washington v. Recuenco, 548 U.S. 212, 222 (2006); see also Neder, 527 U.S. at 15, 19–20 (applying a harmless error analysis to the district court’s determination of an element of a crime when the defendant “did not contest” that element at trial nor did he “suggest that he would introduce any evidence” related to that element if he was re-tried)
State of Minnesota, Respondent, Minn. Ct. App. 2021
“Blakely errors are not structural and thus are subject to a harmless error analysis.” State v. Chauvin
Tevin Marcel Bellaphant, Appellant, Minn. Ct. App. 2020
See State v. 10 Chauvin, (“Blakely errors are not structural and thus are subject to a harmless error analysis,” meaning a reviewing court determines whether the error is harmless beyond a reasonable doubt) (citing Washington v. Recuenco, 548 U.S. 212, 221-22, 126 S. Ct. 2546, 2553 (2006)).
State of Minnesota, Respondent, Minn. Ct. App. 2019
WL 2979382, at *1 (Minn. App. Nov.
State of Minnesota, Respondent, Minn. Ct. App. 2019
A Blakely error does not constitute a “structural error,” Washington v. Recuenco , 548 U.S. 212, 222, 126 S. Ct. 2546, 2553 (2006), and is “subject to a harmless error analysis,”
State of Minnesota, Respondent, Minn. Ct. App. 2019
The supreme court has subsequently explained that “[a] lthough we declined for comity reasons to exercise our inherent judicial authority to authorize sentencing juries [in Barker],” the comity reasons 7 no longer apply “in light of the 2005 legislation retroactively authorizing the use of juries on resentencing.”2 State v. Chauvin , (Mi nn.
State v. Barthman 917 N.W.2d 119 Minn. Ct. App. 2018
State v. Barthman 917 N.W.2d 119 Minn. Ct. App. 2018
State v. Chauvin , , 24 (Minn. 2006) (noting that Blakely errors are subject to harmless-error analysis).
Jamey Ryan Williams Respondent, Minn. Ct. App. 2018
(citing U.S. Const. amends.
State of Minnesota, Respondent, Minn. Ct. App. 2017
(applying harmless error test to Blakely violation).
Back v. State 902 N.W.2d 23 Minn. 2017
Prentis Cordell Jackson v. State of Minnesota 883 N.W.2d 272 Minn. 2016
Prentis Cordell Jackson v. State of Minnesota 883 N.W.2d 272 Minn. 2016
-55 (Minn.2014) ( Fedziuk v. Comm'r of Pub.
State of Minnesota v. Eric Tyler Schwappach Minn. Ct. App. 2016
State of Minnesota v. Eric Tyler Schwappach Minn. Ct. App. 2016
Willie Edd Reynolds v. State of Minnesota 874 N.W.2d 257 Minn. Ct. App. 2016
State of Minnesota v. Benjamin Paul Adams Minn. Ct. App. 2015
State of Minnesota v. Benjamin Paul Adams Minn. Ct. App. 2015
Winhaven Court Apartments v. Sally Carney Minn. Ct. App. 2015
Winhaven Court Apartments v. Sally Carney Minn. Ct. App. 2015
And in the criminal context, courts have stated that a complaint must inform a defendant of the “nature and cause of the accusation” by “contain[ing] such descriptions of the offense charged as will enable him to make his defense” and “to protect him from subsequent prosecution for the same offense.” -30 (Minn. 2006) (quotations omitted); (stating that the allegations against the defendant must not be “so vague under the circumstances as to make it impossible for a defendant to prepare his defen
State of Minnesota v. Ricky Harry Gruber 864 N.W.2d 628 Minn. Ct. App. 2015
State of Minnesota v. Ricky Harry Gruber 864 N.W.2d 628 Minn. Ct. App. 2015
The state meets this requirement “if the charging instrument contains such descriptions of the offense charged as will enable him to make his defense and to plead the judgment in bar of any further prosecution for the same crime.” –30 (Minn. 2006) (quotation omitted).
State of Minnesota v. Mahdi Hassan Ali 855 N.W.2d 235 Minn. 2014
State of Minnesota v. Mahdi Hassan Ali 855 N.W.2d 235 Minn. 2014
makes clear that, in the absence of legislative action, district courts have the inherent judicial authority to conduct a judicial proceeding that is necessary to preserve the constitutionality of a legislative sentencing scheme, and therefore we should remand to the district court for resentencing follow
State v. Essex 838 N.W.2d 805 Minn. Ct. App. 2013
State v. Essex 838 N.W.2d 805 Minn. Ct. App. 2013
State v. M.D.T. 831 N.W.2d 276 Minn. 2013
State v. Randolph 800 N.W.2d 150 Minn. 2011
State v. Randolph 800 N.W.2d 150 Minn. 2011
Accordingly, “safeguarding the rights of criminal defendants is a historical and constitutional function of the judicial branch.” ( State v. Paulick, 277 Minn. 140, 150 , ).
State v. Sailee 792 N.W.2d 90 Minn. Ct. App. 2010
State v. Sailee 792 N.W.2d 90 Minn. Ct. App. 2010
(stating the district court has inherent judicial authority to impanel a sentencing jury).
State v. Rourke 773 N.W.2d 913 Minn. 2009
State v. Adell 755 N.W.2d 767 Minn. Ct. App. 2008
State v. Adell 755 N.W.2d 767 Minn. Ct. App. 2008
“[T]he district court ha[s] the inherent judicial authority to impanel a sentencing jury.” see also Jackson, d at 358 (remanding for the imposition of the presumptive sentence or, unless waived, “the empanelling of a resentencing jury to determine the existence of facts in support of legitimate aggravating factors for enhanced sentencing.”); Jones, d at 851 (remanding for
State v. Spraggins 742 N.W.2d 1 Minn. Ct. App. 2007
State v. Spraggins 742 N.W.2d 1 Minn. Ct. App. 2007
State v. Weaver 733 N.W.2d 793 Minn. Ct. App. 2007
State v. Weaver 733 N.W.2d 793 Minn. Ct. App. 2007
At sentencing, (holding that district courts have inherent judicial authority to impanel sentencing jury for purposes of departing from presumptive sentence).
State v. Jones 733 N.W.2d 160 Minn. Ct. App. 2007
State v. Jones 733 N.W.2d 160 Minn. Ct. App. 2007
In State v. Chauvin, the supreme court clarified that “Blakely did not remove the ability of a judge to impose an aggravated sentence, it only changed the process by which aggravated sentences may be imposed.”
State v. Coleman 731 N.W.2d 531 Minn. Ct. App. 2007
State v. Coleman 731 N.W.2d 531 Minn. Ct. App. 2007
We did not find that this statute is facially unconstitutional, but noted, that *538 the legislature has remained silent regarding how a district court may fulfill this statutory mandate in a constitutional manner because it has not provided guidance as to the proper sentencing procedure for patterned sex offenders who committed
State v. Boehl 726 N.W.2d 831 Minn. Ct. App. 2007
State v. Boehl 726 N.W.2d 831 Minn. Ct. App. 2007
Spears v. State 725 N.W.2d 696 Minn. 2006