LaPenotiere v. State, 916 N.W.2d 351

Defendant Edward LaPenotiere was charged with second-degree sale of a controlled substance in a "school zone" after selling heroin and Vicodin from his home.
Minnesota law defines "school zone" to include school property and "the area surrounding school property ... to a distance of 300 feet or one city block, whichever distance is greater."
LaPenotiere's house sat on a city block kitty-corner (diagonal) to school property; the State introduced an aerial map and officer testimony placing the house on that block but offered no 300-foot measurement.
LaPenotiere sought postconviction relief arguing the one-city-block rule applies only to blocks with a side facing the school (not kitty-corner blocks), so the State had to prove the 300-foot distance, which it did not do.
The postconviction court and court of appeals affirmed; the Minnesota Supreme Court granted review and held that when land is organized in a city-block system, a "school zone" includes the entirety of first-ring blocks, including kitty-corner blocks.
Applying that interpretation, the Court found the map and officer testimony sufficient to support the conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether "one city block" in the school-zone statute includes the entire area of a kitty-corner block when surrounding land is a city-block system	LaPenotiere: "one city block" should be read as a distance for kitty-corner blocks, so the State must prove the 300-foot measure for such blocks	State: "one city block" is an area measurement creating a buffer that includes all first-ring blocks (including kitty-corner)	Held: "one city block" is ambiguous but, construing statute to effectuate legislative purpose, it means area — the school zone includes entire first-ring blocks, including kitty-corner blocks
Whether the evidence was sufficient to prove the school-zone element of the offense	LaPenotiere: Without proof of 300-foot distance, evidence was insufficient because his block is kitty-corner	State: Map and officer testimony locating the house on the first-ring kitty-corner block suffice	Held: Sufficient — aerial map and officer testimony allowed a jury to find the sale occurred within the school zone under the area-based one-block rule

State v. Carufel, 783 N.W.2d 539 (interpreting the park-zone provision and discussing "one city block" as both distance and area)
State v. Benniefield, 678 N.W.2d 42 (describing legislative purpose of school/park zones to protect children from drug-related dangers)
State v. Henderson, 907 N.W.2d 623 (statutory-interpretation standards and de novo review)