Joseph Bergeron v. Tom Roy, Commissioner of Corrections, A16-351

In 1989 Bergeron was convicted of first-degree murder while committing burglary and sentenced to mandatory life imprisonment; the judgment imposed a life sentence.
Minnesota statutes in effect in 1988 established minimum time-served thresholds for parole/supervised release (e.g., 20 or 25 years depending on the subsection) and rules for diminution for good conduct.
Bergeron was released on intensive supervised release in February 2011 with standard conditions (no alcohol, no new crimes).
In October 2014 Bergeron was arrested for DWI and charged with related offenses; a DOC hearing officer found he violated release conditions and he was detained and returned to a correctional facility.
Bergeron filed a habeas petition (Oct 2015) claiming his sentence expired in September 2013 (he read the statutes as making his life sentence effectively a 25-year sentence); the district court dismissed the petition and Bergeron appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Bergeron is unlawfully confined because his sentence expired after 25 years	Bergeron: statutory parole-eligibility language (25-year threshold) means his life sentence expired in 2013	Commissioner: statutory provisions set parole-eligibility minima but do not convert a life sentence into a fixed-term sentence; parolees remain in DOC custody and parole may be rescinded on violation	Court: Affirmed—statutes establish minimum parole eligibility, not maximum sentence; Bergeron remains under commissioner control and may be returned for violations

State v. Bergeron, 452 N.W.2d 918 (Minn. 1990) (affirming Bergeron’s conviction)
State v. Schnagl, 859 N.W.2d 297 (Minn. 2015) (habeas may review DOC decisions implementing a sentence)
State ex rel. Adams v. Rigg, 89 N.W.2d 898 (Minn. 1958) (habeas petitioner bears burden to prove detention unlawful)
Bedell v. Roy, 853 N.W.2d 827 (Minn. App. 2014) (discussing burden in habeas proceedings)