State of Minnesota, Respondent,

This opinion is nonprecedential except as provided by
Minn. R. Civ. App. P. 136.01, subd. 1(c).

STATE OF MINNESOTA
IN COURT OF APPEALS
A25-1469

State of Minnesota,
Respondent,

vs.

Taylor Ann Brown-Snyder,
Appellant.

Filed May 18, 2026
Affirmed
Smith, John, Judge*

Ramsey County District Court
File No. 62SU-CR-23-2539

Keith Ellison, Attorney General, St. Paul, Minnesota; and

Katrina E. Joseph, Gregory P. Holly, H|J LAW, Minneapolis, Minnesota (for respondent)

Cathryn Middlebrook, Chief Appellate Public Defender, Julia Q. Brady, Assistant Public
Defender, St. Paul, Minnesota (for appellant)

Considered and decided by Bratvold, Presiding Judge; Ross, Judge; and Smith,
John, Judge.

* Retired judge of the Minnesota Court of Appeals, serving by appointment pursuant to
Minn. Const. art. VI, § 10.
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NONPRECEDENTIAL OPINION
SMITH, JOHN, Judge
We affirm the district court’s revocation of the a ppellant’s stay of adjudication
because the appellant did not have a liberty interest that prevented the district court from
revoking the stay of adjudication , and the district court did not abuse its discretion in
revoking the stay of adjudication.
FACTS
Appellant Taylor Ann Brown-Snyder pleaded guilty in November 2024 to
gross-misdemeanor domestic assault, stemming from an altercation with her grandmother.
At sentencing the district court stayed adjudication and placed Brown-Snyder on probation
for two years. One of the probation conditions imposed was to “attend and comply with
all mental[-]health court requirement[s].”
The mental-health court required Brown -Snyder to fulfill all mental-health court
terms and conditions, attend support groups and domestic -abuse treatment, and
successfully graduate from mental-health court. Brown-Snyder continued living with her
grandmother.
In March 2025 , during Brown -Snyder’s mental-health court hearing, respondent
State of Minnesota requested the district court issue a domestic-abuse-no-contact order
(DANCO), to protect the grandmother from Brown- Snyder due to “victim safety
concerns.” The district court granted the request and issued the DANCO. In response,
Brown-Snyder became argumentative, yelled profanities, and exited the courtroom before
the hearing concluded.
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At the next mental-health court hearing, Brown-Snyder was informed that her
previous language and conduct would “not be tolerated.” Brown -Snyder was served the
DANCO, which effectively prevented Brown-Snyder from living with her grandmother.
The next month, probation officers conducted a scheduled field visit with
Brown-Snyder. In the subsequent probation-violation report, officers indicated that they
mistakenly went to the grandmother’s house, not Brown-Snyder’s residence. Upon arrival,
the officers discovered that Brown-Snyder had placed padlocks on the grandmother’s
garage and home, “effectively restricting the [grandmother’s] access to her own residence.”
The report stated that the probation officers then went to Brown-Snyder’s residence.
There, Brown- Snyder yelled at the probation officers, us ing derogatory language, and
claimed that the district court was improperly handling her situation. The report further
stated that, despite the officers’ attempts to deescalate the situation, they ultimately needed
to leave for safety reasons. While leaving, Brown-Snyder continued to yell profane insults
at the officers and slammed the door.
The district court terminated Brown-Snyder from mental-health court. The district
court also scheduled a probation-violation hearing because Brown-Snyder failed to comply
with all mental-health court terms and conditions, including successfully completing the
program.
At the probation-violation hearing, Brown -Snyder admitted that she did not
complete mental-health court. Brown-Snyder also submitted letters from her case workers
regarding her mental-health progress. After reviewing the letters, the district court revoked
Brown-Snyder’s stay of adjudication and imposed a stay of imposition of sentence. The
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district court also ordered her to serve 60 days in the Ramsey County jail or on electronic
home monitoring, leaving the choice up to probation, and imposed additional probation
conditions, including attending therapy and mental-health counseling.
DECISION
Stay of Adjudication
Brown-Snyder argues that revoking a stay of adjudication is not an intermediate
sanction under Minnesota law, and the defendant has a liberty interest in the stay of
adjudication once imposed by the district court. Brown-Snyder asserts that because a
defendant has a liberty interest in an imposed stay of adjudication, the district court erred
in revoking her stay of adjudication without applying a factor-based test or additional
fact-finding.
1 Statutory interpretation is a question of law, which Minnesota appellate
courts review de novo. State v. Barrientos, 837 N.W.2d 294, 298 (Minn. 2013). Whether
a defendant has been denied due process is a question of law reviewed de novo. Beaulieu,
859 N.W.2d at 280.
Intermediate Sanctions
Brown-Snyder argues that revoking a stay of adjudication is not an intermediate
sanction under the plain language of Minnesota S tatutes. When interpreting a statute, we
aim to effectuate the intent of the legislature. Minn. Stat. § 645.16 (2024). To do so, we

1 The state argues that because Brown-Snyder did not claim error at the probation-violation
hearing, nor move for modification of her sentence, she is barred from raising the issue to
this court. Yet, our rules state that a district court’s probation-revocation decision is
appealable. Minn. R. Crim. P. 27.04, subd. 3(4)(a); see also State v. Beaulieu, 859 N.W.2d
275, 278 (Minn. 2015) (reviewing probation -violation decision under a constitutional-
violation theory not argued in district court).
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apply canons of construction and the statute’s plain language to resolve any ambiguity.
State v. Powers, 962 N.W.2d 853, 858 (Minn. 2021).
“[Minnesota Statutes] [s]ection 609.14 and Minnesota Rule of Criminal Procedure
27.04 generally address the consequences of a defendant’s violation of the conditions of
probation or intermediate sanctions imposed by the district court.” Barrientos,
837 N.W.2d at 298. Under Minnesota Statutes section 609.14, subdivision 3(3) (2024), if
the court determines that a probation violation occurred, it may “ continue the stay [of
adjudication] without intermediate sanctions, continue [the stay] with intermediate sanctions,
or adjudicate guilt and proceed as otherwise provided.”2
[T]he term “intermediate sanctions” includes but is not limited
to incarceration in a local jail or workhouse, home detention,
electronic monitoring, intensive probation, sentencing to
service, reporting to a day reporting center, chemical
dependency or mental[-]health treatment or counseling,
restitution, fines, day- fines, community work service, work
service in a restorative justice program, work in lieu of or to
work off fines and, with the victim’s consent, work in lieu of
or to work off restitution.

Minn. Stat. § 609.135, subd. 1(b) (2024).

2 The state asserts that this court’s nonprecedential case State v. Thompson, No. A17-0228,
2017 WL 4105216, at *2-3 (Minn. App. Sept. 18, 2017), established that revoking stays of
adjudication are intermediate sanctions. There are two issues with this assertion. First,
this nonprecedential case is not binding authority. See Minn. R. Civ. App. P. 136.01,
subd. 1(c) (stating nonprecedential decisions have no binding authority beyond the specific
case, res judicata, or collateral estoppel ). Second, the legislature amended
Minn. Stat. 609.14, subd. 3 in 2024 to include the above-stated wording. See 2024 Minn.
Laws ch. 123, art. 6, § 12, at 2291. Thompson was issued seven years before the
amendment. Thus, Thompson also lacks persuasive authority related to this issue.
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The wording within section 609.14, subdivision 3(3), separates the continuation or
revocation of a stay of adjudication from the imposition of an intermediate sanction. It
identifies them as distinct actions. Similarly, section 609.135, subdivision 1(b) does not
include the imposition of a stay within its list of intermediate sanctions. We recognize that
the list “is not limited to” those specified. Yet, we interpret statutory lists under the doctrine
of ejusdem generis—that “general language that follows a listing of specific subjects is
presumed to be limited to subjects similar to those expressly listed.” State v. Eide, 898
N.W.2d 290, 295 (Minn. App. 2017) ; accord State v. Sanschagrin, 952 N.W.2d 620, 627
(Minn. 2020); see also Minn. Stat. § 645.08(3) (2024) (codifying ejusdem generis). The
list provided by the legislature includes types of incarceration, work services, and
probationary conditions; it does not include stays of sentencing, including a stay of
execution, imposition, or adjudication. Based on the plain wording of Minnesota statutes,
the revocation of a stay of adjudication is not an intermediate sanction.
Liberty Interest
Brown-Snyder argues that a defendant has a liberty interest in a stay of adjudication
imposed by the district court. Both the United States and Minnesota Constitutions protect
against deprivation of liberty without due process of law. U.S. Const. amend. XIV, § 1;
Minn. Const. art. I, § 7. “A stay of adjudication . . . is a unique judicial tool.” State v. Lee,
706 N.W.2d 491, 494 (Minn. 2005). “[It] permits the district court to impose conditions
of probation, including jail time, without a formal adjudication of guilt or the imposition
of a sentence.” State v. Greenough, 915 N.W.2d 915, 918 (Minn. App. 2018)
(quotation omitted).
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The district courts have limited authority to order a stay of adjudication.
See State v. Martin, 849 N.W.2d 99, 102 (Minn. App. 2014), rev. denied (Minn. Sept. 24,
2014). Specifically,
[e]xcept as provided in section 152.18, 609.1056,
609.375, or upon agreement of the parties, a court may not
refuse to adjudicate the guilt of a defendant who tenders a
guilty plea in accordance with Minnesota Rules of Criminal
Procedure, rule 15, or who has been found guilty by a court or
jury following a trial.

Minn. Stat. § 609.095(b) (2024) (emphasis added). Additionally, the courts may order a
stay of adjudication to address injustice resulting from a prosecutor’s clear abuse of its
discretion in the exercise of the charging function. State v. Foss, 556 N.W.2d 540, 541
(Minn. 1996).
This framework reflects the unique and special nature of a stay of adjudication. It
is an extraordinary disposition authorized only by statute and permitted only upon the
agreement of the parties or when judicial intervention is necessary to correct a clear abuse
of the prosecutorial charging function. Given that a stay of adjudication is available only
to a narrow class of defendants under limited conditions, it is difficult to conclude that a
protected liberty interest arises from such a discretionary and circumscribed disposition.
Brown-Snyder argues that a defendant has a liberty interest because of the collateral
consequences of the disposition. However, consequences come with committing the
offense. See State v. Twiss, 570 N.W.2d 487, 487 (Minn. 1997) (stating that loss of job
resulting from conviction is not a special circumstance allowing district court to stay
adjudication; rather, “it is the sort of consequence that commonly attends a conviction of a
8
serious offense”). Indeed, we have rejected attempts to argue that collateral consequences
justify granting a stay of adjudication. See, e.g., State v. Angotti, 633 N.W.2d 554, 557
(Minn. App. 2001) (concluding defendant’s potential loss of their business due to
conviction is not a special circumstance allowing district court to order stay of adjudication
over prosecutor’s objections); State v. Leming, 617 N.W.2d 587, 589 (Minn. App. 2000)
(concluding same regarding defendant’s lack of criminal record). In other words, the
collateral consequences of the defendant’s actions do not establish a liberty interest. Thus,
a defendant does not have a liberty interest in a stay of their adjudication by the district
court.
Because we conclude that a defendant does not have a liberty interest in a stay of
adjudication, we need not reach the issue of whether a factor-based test is needed to protect
the alleged liberty interest. As such, the district court did not err by revoking
Brown-Snyder’s stay of adjudication without providing a detailed fact-finding explanation.
Abuse of Discretion
Brown-Snyder also argues that the district court abused its discretion by revoking
her stay of adjudication. “The [district] court has broad discretion in determining if there
is sufficient evidence to revoke probation and should be reversed only if there is a clear
abuse of that discretion.” State v. Austin, 295 N.W.2d 246, 249-50 (Minn. 1980). “On
appeal, the appellant has the burden of establishing that the district court abused its
discretion and that appellant was thereby prejudiced.” State v. Nowacki, 880 N.W.2d 396,
399 (Minn. App. 2016) (quotation omitted). “A district court abuses its discretion when it
acts arbitrarily, capriciously, or contrary to legal usage.” Id. (quotation omitted).
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Here, Brown-Snyder was terminated from mental-health court. This termination
prevented her from successfully graduating, which was a requirement of the program. The
failure to comply with the program requirements was a violation of her conditions of
probation. Upon admitting to the violation, the district court revoked the stay of
adjudication. Based on the record, the district court did not abuse its discretion by revoking
Brown-Snyder’s stay of adjudication.
Brown-Snyder argues that the district court was not required to revoke her stay of
adjudication under the terms of the plea agreement. However, there is nothing in the record
indicating that the district court’s decision to revoke the stay of adjudication was based on
the plea deal; the record reflects only that it was based on the probation violation.
Brown-Snyder also argues that the district court’s revocation of the stay of
adjudication was unnecessary and should have addressed the violation with intermediate
sanctions. This is a disagreement with the court’s decision, not an argument that the district
court abused its discretion in its decision. See State v. Garland, 942 N.W.2d 732, 742
(Minn. 2020) (“A district court abuses its discretion when its decision is based on an
erroneous view of the law or is against logic and the facts in the record.” (quotation
omitted)). There was no abuse of discretion by the district court in revoking
Brown-Snyder’s stay of adjudication.
Affirmed.