State v. Robinette
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The Supreme Court affirmed the judgment of the court of appeals affirmed Defendant's conviction but remanding the case to the district court for Defendant to be resentenced in accordance with modified guidelines, holding that the court of appeals did not err.
Defendant was convicted and sentenced for criminal sexual conduct. At issue on appeal was whether a Minnesota Sentencing Guideline and associated commentary adopted by the Minnesota Sentencing Guidelines Commission but not ratified by the Legislature could abrogate the common law amelioration doctrine, which applies to a statute that mitigates the punishment for "acts committed before its effective date, as long as no final judgment has been reached." The court of appeals held (1) unratified statements by the Minnesota Sentencing Guidelines Commission could not abrogate the amelioration doctrine because they did not constitute a "statement by the Legislature"; and (2) Defendant was entitled to the benefit of a change in the Sentencing Guidelines adopted by the Commission in 2019, which resulted in a reduction of Defendant's criminal history score. The Supreme Court affirmed, holding that Defendant was entitled to resentencing under the amelioration doctrine.
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