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“Generally, a search is valid, with a few exceptions, only if conducted pursuant to a valid warrant.”

A district court may impose multiple convictions for “different incidents (counts) arising out of a single behavioral incident,” but it may not impose “multiple sentences for 13 conduct that is part of a single behavioral incident.” (quotation omitted); see Minn. Stat. § 609.035, subd.

Minnesota law recognizes “a distinction between sentencing on multiple convictions that arose from a single behavioral incident and convictions of more than one offense arising from the same act.”

State v. Papadakis , see Minn. Stat. § 609.035 (2022).

“Generally, a search is valid, with a few exceptions, only if conducted pursuant to a valid warrant.” d 349, 355 (Minn. App. 2002).

357-58 (Minn. App. 2002).

15a(3) (2022) (defining “sell” to include “possess[ing] with intent” to sell); (explaining that knowledge is an element of a crime of controlled-substance possession).

27, 2019); -57 (Minn. App. 2002) (a district court has authority to reconsider its own rulings).

d 349, 358 (Minn. App. 2002).

1(2); (“To sustain a conviction, the state must prove all essential elements of the charged crime beyond a reasonable doubt.”).

Minn. Stat. § 609.035; (“Minn. Stat. § 609.035 allows multiple convictions for different incidents (counts) arising out of a ‘single behavioral incident,’ but prohibits multiple sentences for conduct that is part of a single behavioral incident.”).

State v. Papadakis , - 40 (Minn. 1994) (reversing conviction because scientific evidence of weight —an element of the charged offense —was insufficient because of inadequate random sampling) ; (“If an alleged of

16, 2010); (“We conclude that possession of a controlled substance and knowledge of the nature of the substance are essential elements, but that the state does not have to prove, in addition to all other elements, that appellant knew the precise weight or quantity of the controlled-substance.”); State v

356 (Minn. App. 2002) (affirming denial of suppression motion when search-warrant affidavit stated that within 72 hours of applying for search warrant, officers recovered trash containing cocaine residue).

To qualify as the “same crime” for the purposes of section 609.04, the offenses must be a “single criminal act.”

Crimes arise from the same behavioral incident if they “occurred at substantially the same time and place and were motivated by a single criminal objective.” see, (concluding that the defendant’s simultaneous possession of different drugs in his home was a single behavioral incident resulting in only one sentence).

(concluding that simultaneous possession of different drugs in defendant’s house were separate criminal acts and permitted multiple convictions).

the district court has the inherent authority to consider such a motion.” -57 (Minn. App. 2002); see also State 6 v. Montjoy, -49 (Minn. 2008).

uct constitutes more than one offense under the laws of this state, the person may be punished for only one of the offenses.”); State v. Ferguson , (explaining that Minn. Stat. § 609.035 “contemplates that a defendant will be punished for the most serious of the offenses arising out of a single behavioral incident” (quotation omitted)); State v. Papadakis , (“Possession of two controlled substances at the same tim e and place, for personal use, is a single behavioral incident.”); State v. Reese

In support of his argument that the dist rict court erred in entering separate convictions, Shaka cites State v. Papadakis , (Mi nn.

-57 (Minn. App. 2002) (recognizing that the district court has discretion to grant or deny a party’s motion to reconsider an omnibus ruling).

that, unlike claims pu rsuant to section 609.035, post conviction claims based on section 609.04 are not properly brought under rule 27.03 of the Minnesota Rules of Criminal Procedure because section 609.04 relates to convictions, not sentences); Spears, d at 726-27 (conducting a separate analysis of sentences under section 609.035 and convictions under 609.04); (affirming district court’s decision to enter multiple convictions under s ection 609.04 and affirming district court’s decision to imp

(stating that “doubtful cases should be resolved by the preference for warrants”).

State v. Papadakis , (stating that “doubtful cases should be resolved by the preference for wa rrants”).

“Marginal or doubtful cases should be resolved by the preference for warrants.”

See State v. Papadakis , (holding that multiple convic tions for possession of different drugs on the same day were appropriate, but multiple sentences were not).

See State v. Montjoy , , 107-08 (Minn. 1985) ; see also State v. Papadakis , , 356-57 (Minn. App. 2002) (acknowledging district court's authority to consider motions to reconsider and stating that a motion to reconsider "may be the most efficient and preferable course of action" because it can spare parties the time and expense of appeal).

As a result, section 609.035 “allows multiple conv ictions for different [offens es] arising out of a single behavioral incident.” State v. Papadakis , (quotation omitted).

-57 (Minn. App. 2002) (-08 (Minn. 1985)).

2(a); (outlining the elements of possession crimes).

“Although the rules of criminal procedure do not specifically authorize motions for reconsideration of omnibus rulings, the district court has the inherent authority to consider such a motion.” State v. Papadakis , -57 (Minn. App. 2002); (remanding for reopened omni bus hearing).