Cited by

2 In doing so, –82 (Minn. 2016), limited its discretion to impose the sentences consecutively.

The district court, however, had these sentences run concurrently, concluding that our decision in Jackson v. State , precluded consecutive sentences.

Release is not automatic because “pu blic safety and the interests of the victims’ families will be carefully considered before any eventual release could be approved.” State v. Ali , (Chutich, J., dissenting); see also Jackson v. State , n. 8 (Minn. 2016) (detailing statutory steps that must occur before supervised release of an offender is authorized).

See, e.g., Campbell, d at 507 (noting that while “the affidavit is notarized, it contains multiple layers of hearsay”); Jackson v. State , –78 (Minn. 2016) (refusing to admit a witness’s written statement under Rule 804(b)(3) after he asserted his Fifth Amendment right against self -incrimination); Ferguson, d at 812 –13 (same); State v. Richardson , –67 (Minn. 1986) (same).

“Under the statement -against-interest exception, ‘a statement tending to expose the 12 declarant to criminal liability and offered in a criminal case i s not admissible unless corroborating circumstances clearly indicate the trustworthiness of the statement.’” (quoting Minn. R. Evid.

Nelson contends that the Miller/Montgomery rule applies with equal force to him, an 18-year-old offender, because an evolving scientific and national consensus shows that there are no material neurodevelopmental differences between juveniles and 18 year olds.6 We considered the Miller/Montgomery rule for the first time in Jackson v. State

Montgomery v. Louisiana, ___ U.S. ___, 136 S. Ct. 718, 732 (2016); (acknowledging that Montgomery “holds that the Miller rule applies retroactively”).

Jackson v. State ( Jackson II ), , 275 (Minn. 2016).

First, Crow expresses frustration that the sentence of his codefendant, J.P., who was a minor when the crime occurred, was recently reduced from life in prison without the possibility of release to life in prison with the possibility of release in accordance with Jackson v. State

Jackson v. State , , 278 (Minn. 2016).

does not limit a district court’s authority to impose consecutive sentences of life imprisonment with the possibility of release upon a juvenile offender.