Cited by
Opinions in Minnesota that cite State v. Soto, 562 N.W.2d 299.
- Karl Alfredo Rosillo, petitioner, Appellant, vs. State of Minnesota, Respondent Minn. Ct. App. 2025
- Karl Alfredo Rosillo, petitioner, Appellant, vs. State of Minnesota, Respondent Minn. Ct. App. 2025
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State of Minnesota, Respondent,
Minn. Ct. App. 2025
And, in State v. Soto, the supreme court concluded that a cocaine dealer’s “objective of selling drugs to relieve financial hardship” did not mean that 29 separate cocaine sales shared a “single criminal objective” because a “criminal plan of obtaining as much money as possible is too broad an objective to constitute a single criminal goal within the meaning of section 609.035.”
- State of Minnesota v. Rafael Antonio Segura-Arroyo Minn. Ct. App. 2024
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State of Minnesota v. Rafael Antonio Segura-Arroyo
Minn. Ct. App. 2024
rnandez method, “when a defendant is sentenced for multiple offenses[, not arising from a single course of conduct,] on the same day, a conviction for which the defendant is first sentenced is added to his or her criminal-history score for 7 another offense for which he or she is also sentenced.” Williams, d at 522 ( (explaining the Hernandez method)).
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State of Minnesota, Respondent,
Minn. Ct. App. 2023
This analysis “is not a mechanical test, but involves an examination of all the facts and circumstances.” (quotation omitted); see also Degroot, d at 365 (“Whether a defendant’s multiple offenses were part of a single behavioral incident depends on the facts and circumstances of the case .
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State of Minnesota, Respondent,
Minn. Ct. App. 2023
We use several factors to determine whether tw o or more offenses arose from a single behavioral incident , including “time, place, and whether the offenses were motivated by a desire to obtain a single criminal objective.” d 299, 304 (Minn. 1997).
- State of Minnesota, Respondent, Minn. Ct. App. 2023
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State of Minnesota, Respondent,
Minn. Ct. App. 2023
The determination does not involve a “mechanical test,” but “an examination of all the facts and circumstances.”
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State of Minnesota, Respondent,
Minn. Ct. App. 2022
“Determining whether multiple offenses are part of a single behavioral incident is not a ‘mechanical’ exercise, but rather requires an examination of all the facts and circumstances.” ().
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State of Minnesota, Respondent,
Minn. Ct. App. 2022
“Under section 609.035, the factors to be considered in determining whether multiple offenses constitute a single behavioral act are time, place, and whether the offenses were motivated by a desire to obtain a single criminal objective.” see also Bakken, d at 270.
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State of Minnesota, Respondent,
Minn. Ct. App. 2021
Determining whether that standard is met is not a “mechanical” exercise but “involves an examination of all the facts and circumstances.”
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A19-1493
Minn. Ct. App. 2020
20 objective); (concluding that selling drugs to relieve financial hardship is too broad to constitute a single criminal objective); (concluding that “general hatred of women,” is too broad to constitute a single criminal objective) ; Jackson, d at 394
- State of Minnesota, Respondent, Minn. Ct. App. 2020
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State of Minnesota, Respondent,
Minn. Ct. App. 2020
See State v. Bauer , (affirming multiple sentences because sharing illegal drugs with friends is too broad to constitute a single criminal objective); State v. Gould , (affirming use of the Hernandez method because relieving financial hardship is too broad to constitute a single criminal objective); (affirming use of Hernandez method because selling drugs to relieve financial hardship is too broad to constitute a single criminal objective); ( affirming multiple sentences because the identified c
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State of Minnesota, Respondent,
Minn. Ct. App. 2019
State v. Soto , State v. Carr
- State of Minnesota, Respondent, Minn. Ct. App. 2019
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State of Minnesota, Respondent, vs. Michael Anthony Pitts, Appellant.
Minn. Ct. App. 2019
(quotation omitted); (“Under section 609.035, the factors to be considered in determining whether multiple offenses constitute a single behavioral act are time, place, and whether the offenses were motivated by a desire to obtain a single criminal objective.”).
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State of Minnesota, Respondent,
Minn. Ct. App. 2019
(“[O]btaining as much money as possible is too broad an objective to constitute a single criminal goal within the meaning of section 609.035.”), with Langdon v. State , (concluding that stealing “as much money as he could that afternoon from the coin boxes on the
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State of Minnesota, Respondent,
Minn. Ct. App. 2019
But different outcomes in different cases can be expected becau se the analysis is “not a mechanical test, but involves an examination of all the facts a nd circumstances.”
- State of Minnesota, Respondent, Minn. Ct. App. 2018
- State of Minnesota, Respondent, Minn. Ct. App. 2018
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State of Minnesota, Respondent,
Minn. Ct. App. 2018
But different outcomes in different cases can be expected as this analysis is, after all, “not a mechanical test, but involves an examination of all the facts and circumstances.”
- State of Minnesota, Respondent, Minn. Ct. App. 2018
- State of Minnesota, Respondent, Minn. Ct. App. 2018
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State of Minnesota, Respondent,
Minn. Ct. App. 2018
We also consider whether the offenses “arose from a continuous and uninterrupted course of conduct” and whether the offender “manifested an indivisible state of mind.” State v. Johnson , see also State v. Soto , State v. Chidester , review denied (Minn. Mar.
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State of Minnesota, Respondent,
Minn. Ct. App. 2018
“Under section 609.035, the factor s to be considered in determining whether multiple offenses constitute a single behavioral act are ti me, place, and whether the offenses were motivated by a desire to obtain a single criminal objective.”
- State of Minnesota, Respondent, Minn. Ct. App. 2018
- State of Minnesota, Respondent, Minn. Ct. App. 2018
- State of Minnesota v. Timothy John Bakken 883 N.W.2d 264 Minn. 2016
- State of Minnesota v. Timothy John Bakken 883 N.W.2d 264 Minn. 2016
- State of Minnesota v. Marlow Shelton McDonald Minn. Ct. App. 2016
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State of Minnesota v. Marlow Shelton McDonald
Minn. Ct. App. 2016
The Minnesota Supreme Court has declined to adopt the doctrine of sentencing manipulation “in the absence of egregious police conduct which goes beyond legitimate investigative purposes.”
- State of Minnesota v. Cedric Chappell, Jr. Minn. Ct. App. 2016
- State of Minnesota v. Cedric Chappell, Jr. Minn. Ct. App. 2016
- State of Minnesota v. Arteco Marvell Rhodes Minn. Ct. App. 2015
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State of Minnesota v. Arteco Marvell Rhodes
Minn. Ct. App. 2015
(stating that whether multiple offenses are part of a single behavioral act involves an examination of all the facts).
- State of Minnesota v. Stephanie JoNell Guscette Minn. Ct. App. 2015
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State of Minnesota v. Stephanie JoNell Guscette
Minn. Ct. App. 2015
two or more intentional crimes; in that situation, “Minnesota courts consider whether the conduct (1) shares a unity of time and place and (2) was motivated by an effort to obtain a single criminal objective.” (Bauer I) ( aff’d, ); ).
- State v. Cogger 802 N.W.2d 407 Minn. Ct. App. 2011
- State v. Cogger 802 N.W.2d 407 Minn. Ct. App. 2011
- State v. Bauer 776 N.W.2d 462 Minn. Ct. App. 2009
- State v. Bauer 776 N.W.2d 462 Minn. Ct. App. 2009
- State v. Williams 771 N.W.2d 514 Minn. 2009
- State v. Williams 771 N.W.2d 514 Minn. 2009
- State v. O'MEARA 755 N.W.2d 29 Minn. Ct. App. 2008
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State v. O'MEARA
755 N.W.2d 29
Minn. Ct. App. 2008
involves an examination of all the facts and circumstances.”
- State v. Suhon 742 N.W.2d 16 Minn. Ct. App. 2007
- State v. Suhon 742 N.W.2d 16 Minn. Ct. App. 2007
- State v. Hager 727 N.W.2d 668 Minn. Ct. App. 2007