Cited by

Midwest also argues that the purpose of bail was satisfied because Bruce was absent for about three months and that we have “found the purpose of bail satisfied in cases with a similar period,” citing Askland, d at 63, Storkamp, d at 543

For example, the surety was successful on appeal because it had “made numerous attempts to locate [the defendant] through contacts with family, friends, and multi-state law enforcement,” which “ultimately led to [the defendant’s] arrest.” Id.

First, it contends that courts have found the purpos e of bail satisfied when defendants were apprehended after failing to appear for similar periods of time, citing Farsdale v. Martinez, 6 -25 (Minn. App. 1998), Askland, d at 61, and a nonprecedential decision of this court.

12, 2015) (reversing forfeiture of bond by district court where defendant entered a guilty plea, failed to appear at sentencing, and was at large for 64 days); -26 (Minn. App. 8 1998) (reversing forfeiture of bond where defendant entered a guilty plea, failed to appear at sentencing, and was at large for approximately “two months”).

In support of this proposition, Midwest cites Askland, d at 62, -25 (Minn. App. 1998), and a nonprecedential decision.1 We see no abuse of discretion in the district court’s evaluation of the first factor.

See Askland, d at 61 (approximately seven months) ; Farsdale v. Martinez , -25 (Minn. App. 1998) (approximately two months); State v. Stellmach, No. A14 -0920, 2015 WL 134174 , at *1 (Minn. App. Jan.

Yet, Midwest argues that the purpose of bail was fulfilled here because White only absconded after pleading guilty, 5 In Farsdale, we concluded that forfeiting a bond after the defendant had pleaded guilty would be contrary to the primary purpose of bail, which is to secure a defendant’s presence at trial.

See Askland, d at 61 ( defendant at large for about seven months); Storkamp, d at 540 –41 (defendant at large for about two months); –25 (Minn. App. 1998) (defendant at large for about two months).

5 seven months); -25 (Minn. App. 1998) (about three months).

ted reinstatement in the absence of any evidence of prejudice to state); Storkamp, d at 540-41, 543 (bond company made “good-faith efforts” to track down and successfully apprehend defendant, incurring $1,200 3Askland, d at 61 (about seven months); Storkamp, d at 540-41 (about two months); -25 (Minn. App. 1998) (about two months).

KSI’s d 423 (Minn. App. 1998), which “made numerous attempts to locate [the defendant] through contacts with family, friends, and multi -state law enforcement,” which “ultimately led to 10 [the defendant’s] arrest.” Id.

e state experienced no prejudice); Shetsky, 239 Minn. at 474, d at 48 (affirming the forfeiture because the surety made no effort to arrest or pr oduce the defendant before relieving itself of liability); Vang, d at 359 (affirming forfeiture of majority of bond where efforts of the surety did not lead to the return of defendant, who remained at large); (reversing forfeiture of bond based, in part, on the surety’s aid in locating the absent defendant); 278 (Minn. App. 1988) (affirming forfeiture

See Askland, d at 61 (about seven months); Storkamp, d at 540-41 (about two months); -25 (Minn. App. 1998) (about three months).

d 423, 425 (Minn. App. 1998) (applying the Shetsky factors to determine whether a district court abused its discretion in a bond-forfeiture decision).

-26 (Minn. App. 1998) (concluding that appearance bond served its primary purpose of securing defendant’s appearance at trial when defendant was secured after being at large “for only two months”); cf. Vang, d at 358 (noting that surety had not achieved one of the purposes of bail when it failed to re