Cited by
Opinions in Minnesota that cite Kaiser v. State, 641 N.W.2d 900.
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State of Minnesota, Respondent,
Minn. Ct. App. 2026
“[A] direct consequence is one that has a definite, immediate and automatic effect on the range of a defendant’s punishment.” Kaiser v. State , n.6 (Minn. 2002).
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Ricardo Daniel Peralta Gutierrez, petitioner, Appellant,
Minn. Ct. App. 2026
“A direct consequence is one that has a definite, immediate and automatic effect on the range of a defendant’s punishment.” d 693, 697 (Minn. App. 2004) (d 900, 904 n.6 (Minn. 2002)).
- State of Minnesota v. Oluwatoyin Emmanuel Aina Minn. Ct. App. 2026
- State of Minnesota v. Oluwatoyin Emmanuel Aina Minn. Ct. App. 2026
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State of Minnesota, Appellant,
Minn. Ct. App. 2025
“[A] direct consequence is one that has a definite, immediate and automatic effect on the range of a defendant’s punishment.” n.6 (Minn. 2002).
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State of Minnesota, Respondent,
Minn. Ct. App. 2025
(distinguishing between direct and collateral consequences of a guilty plea).
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In the Matter of the Welfare of: C. P. M., Child.
Minn. Ct. App. 2025
A 12 collateral consequence—a consequence that does “not flow definitely, immediately, and automatically”—is “not punishment.” (), rev. denied (Minn. May 21, 2013).
- State of Minnesota v. Kenneth Jagger Crawford Minn. Ct. App. 2024
- State of Minnesota v. Kenneth Jagger Crawford Minn. Ct. App. 2024
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Chad Alan Hoflock, petitioner, Appellant,
Minn. Ct. App. 2024
In contrast, collateral consequences are those that “serve a substantially different purpose” other than to punish and are “civil and regulatory in nature.”
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State of Minnesota, Respondent,
Minn. Ct. App. 2024
at 568 ( n.6 (Minn. 2002)).
- Travis Clay Andersen, petitioner, Appellant, Minn. Ct. App. 2024
- Nathan Alexander Jefferson v. Drew Evans Minn. Ct. App. 2024
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Nathan Alexander Jefferson v. Drew Evans
Minn. Ct. App. 2024
(holding that the statutory duty to register as a predatory offender is a collateral consequence of a guilty plea because it is not part of defendant’s punishment).
- Fidele Ndaruhutse v. State of Minnesota Minn. Ct. App. 2024
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Fidele Ndaruhutse v. State of Minnesota
Minn. Ct. App. 2024
A party may withdraw a guilty plea after sentencing when it “is necessary to correct a manifest injustice.”
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Justin Lee Ironhawk, petitioner, Appellant,
Minn. Ct. App. 2024
(concluding that the duty to register as a predatory offender is not punitive, but instead is a regulatory, collateral consequence); Minn. Stat. § 243.166, subd.
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State of Minnesota, Respondent,
Minn. Ct. App. 2024
17 In Kaiser v. State, the supreme court stated that “[s]ex offender registration is a direct consequence of the offender’s guilty plea if for no other reason than [it is mandated by statute].”
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Sophia Wang Navas, petitioner, Appellant,
Minn. Ct. App. 2023
27, 2022); (explaining that “direct consequences are those related to punishment that flow definitely, immediately and automatically from the plea” and include “the maximum sentence and fine”).
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State of Minnesota, Appellant,
Minn. Ct. App. 2023
“The duty to register as a predatory offender is a regulatory rather than punitive consequence.”
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State of Minnesota, Respondent,
Minn. Ct. App. 2023
(defining “collateral consequences” as those that do not punish and are not intended to punish but that do serve the interest of public safety); (explaining that “direct consequences are those related to punishment that flow definitely, immediately and automatically from the plea” and include “the maximum sentence and fine”).
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State of Minnesota, Respondent,
Minn. Ct. App. 2023
Collateral consequences, in contrast, are those which do not punish, “‘serve a substa ntially different purpose ’ than to punish, and ‘are imposed in the interest of public safety.’” Bell, d at 101 (d 900, 905 (Minn. 2002) ).
- Martin Matthew Lange, Appellant, Minn. Ct. App. 2022
- Mary Kate Nguyen, Appellant, Minn. Ct. App. 2022
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Majed Issac Ijong, petitioner, Appellant,
Minn. Ct. App. 2022
Rather, the defendant must be aware of the direct consequences of his plea, which are those consequences that are “definite, immediate and automatic.” d 900, 903, 907 (Minn. 2002).
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State of Minnesota, Respondent,
Minn. Ct. App. 2022
Collateral consequences, by contrast, are those that do not punish, “serve a substantially different purpose” than to punish, a nd “are imposed in the interest of public safety.” Kaiser v. State
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State of Minnesota, Respondent,
Minn. Ct. App. 2021
To be valid, a guilty plea must be “accurate, voluntary, and intelligent.”
- Dylan Matthew Deling, petitioner, Appellant, Minn. Ct. App. 2021
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State of Minnesota, Respondent,
Minn. Ct. App. 2021
See, -04, 907 (Minn. 2002) (stating defendant must be informed of direct consequences but not collateral consequences).
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State of Minnesota, Respondent,
Minn. Ct. App. 2021
“A defendant need not be advised of every consequence for his plea to be intelligent” and “[i]gnorance of a collateral consequence does not entitle a criminal defendant to withdraw a guilty plea.” -04 (Minn. 2020) (emphasis omitted).
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S’Emaj Avyiair Okongwu, petitioner, Appellant,
Minn. Ct. App. 2021
Kaiser v. State , -04 (Minn. 2002).
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State of Minnesota, Respondent,
Minn. Ct. App. 2020
To be valid, a guilty plea must be “accurate, voluntary, and intelligent.”
- State of Minnesota, Respondent, vs. Nyla Tomeka Murrell-French, Appellant. Minn. Ct. App. 2020
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State of Minnesota, Respondent,
Minn. Ct. App. 2020
A manifest injustice occurs when a guilty plea is invalid, meaning it is not “accurate, voluntary, and intelligent.”
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State of Minnesota, Respondent,
Minn. Ct. App. 2020
Regarding the intelligence of the plea, a defendant need not be advised of every consequence of a plea, and need only be advised of “direct consequences.” -04 (Minn. 2002).
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State of Minnesota, Respondent,
Minn. Ct. App. 2019
d 900, 903 (Minn. 2002) (“Public policy favors the finality of judgments .
- Bedeau v. Evans 926 N.W.2d 425 Minn. Ct. App. 2019
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Bedeau v. Evans
926 N.W.2d 425
Minn. Ct. App. 2019
See Kaiser v. State , , 904 (Minn. 2002) ("The court of appeals was correct ...
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State of Minnesota, Respondent,
Minn. Ct. App. 2019
To permit otherwise would, no doubt, undermine the purpose of the registration statute, which is “ to keep law enforcement informed as to a predatory offender’s whereabouts.” (“The Minnesota Supreme Court has emphasized that the registration statute reflects a policy that society has the right to know the location of predatory offenders, not in order to punish them, but to protect the public.”), revi
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State of Minnesota, Respondent,
Minn. Ct. App. 2018
To be valid, a guilty plea must be “accurate, voluntary, and intelligent.”
- Chester Vernon Jones, Appellant, Minn. Ct. App. 2018
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State of Minnesota, Respondent,
Minn. Ct. App. 2018
To be valid, a guilty plea must be “accurate, voluntary, and intelligent.”
- In the Matter of the Welfare of: C. G. H., Child Minn. Ct. App. 2018
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State of Minnesota, Respondent,
Minn. Ct. App. 2017
The direct consequences of a guilty plea, such as the maximum sentence and f ine for the offense, “flow definitely, immediately, and automatically from the guilty plea.” Kaiser v. State
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State of Minnesota, Respondent,
Minn. Ct. App. 2017
The direct consequences of a plea “are those which flow definitely, immediately, and automatically from the guilty plea.” (quotation omitted).
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State of Minnesota, Respondent,
Minn. Ct. App. 2017
Kaiser v. State , review denied (Minn. Feb.
- State v. LaFountain 901 N.W.2d 441 Minn. Ct. App. 2017
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State v. LaFountain
901 N.W.2d 441
Minn. Ct. App. 2017
In assessing whether the registration statute is penal in nature under Mendoza-Martinez , we are guided by three cases that applied this framework to predatory-offender statutes: ; and Smith v. Doe, 538 U.S. 84 , 128 S.Ct.
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Daniel Onguenyi Nyagoko, petitioner, Respondent,
Minn. Ct. App. 2017
Kaiser v. State , (M inn.
- Dikken v. State 896 N.W.2d 873 Minn. 2017