Junious Taylor, Jr. v. State of Minnesota, 887 N.W.2d 821

Junious Taylor pleaded guilty to felony domestic assault in Ramsey County on October 22, 2013.
Neither the court, the prosecutor, nor defense counsel advised Taylor at plea or sentencing that the conviction would trigger Minnesota predatory-offender registration under Minn. Stat. § 243.167.
Corrections discovered post-sentencing (March 2014) that Taylor — previously convicted of criminal sexual conduct in 1989 — now had a new registration duty; Taylor moved to withdraw his guilty plea.
The district court denied the motion; the court of appeals affirmed, concluding the registration requirement is a collateral consequence and counsel’s failure to advise was not ineffective assistance.
The Minnesota Supreme Court granted review solely on the ineffective-assistance claim and affirmed the court of appeals, holding Padilla v. Kentucky did not compel overturning Kaiser v. State.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether predatory-offender registration is a collateral consequence of a guilty plea	Taylor: registration is a direct, substantial consequence that must be advised before a plea	State: registration is collateral (as in Kaiser), so no duty to advise before plea	Held: Registration is a collateral consequence.
Whether Padilla v. Kentucky overruled Kaiser v. State and requires counsel to advise about registration	Taylor: Padilla’s reasoning on deportation extends to other severe consequences like registration	State: Padilla rested on deportation’s unique severity; it does not control here	Held: Padilla does not compel overturning Kaiser; deportation is materially different and more severe.
Whether counsel’s failure to advise about registration constituted ineffective assistance under Strickland	Taylor: counsel’s omission made his plea unintelligent and involuntary	State: counsel is not constitutionally deficient for failing to advise about collateral consequences	Held: No ineffective assistance; counsel’s failure did not render the plea unintelligent.
Whether Taylor is entitled to withdraw his guilty plea based on counsel’s omission	Taylor: withdrawal necessary to correct manifest injustice because plea was unintelligent	State: no manifest injustice where plea was voluntary and intelligent despite collateral consequence	Held: Denial of plea-withdrawal affirmed; no manifest injustice.

Strickland v. Washington, 466 U.S. 668 (1984) (two-prong test for ineffective assistance of counsel)
Padilla v. Kentucky, 559 U.S. 356 (2010) (counsel must advise noncitizen defendants about deportation risk)
Kaiser v. State, 641 N.W.2d 900 (Minn. 2002) (Minnesota: predatory-offender registration is a collateral consequence)
Alanis v. State, 583 N.W.2d 573 (Minn. 1998) (distinguishing direct vs. collateral consequences for plea advice)
Smith v. Doe, 538 U.S. 84 (2003) (sex-offender registration deemed nonpunitive for Eighth Amendment purposes)
Chaidez v. United States, 133 S. Ct. 1103 (2013) (Padilla relied on deportation’s unique characteristics)
Trott v. State, 330 P.3d 1267 (Utah 2015) (similar conclusion that Padilla does not extend to sex-offender registration)