State of Minnesota, Respondent/Cross-Appellant v. Brian Keith Schnagl, a/k/a Brian Keith Schnagel, Appellant/Cross-Respondent., 859 N.W.2d 297

In 2000 Schnagl was adjudicated for first-degree criminal sexual conduct and given a stayed 98‑month sentence with a 5‑year conditional‑release term; the sentence was later executed and he served part of it before release to supervised/conditional release.
Schnagl incurred multiple supervised‑release violations, was returned to custody, and the DOC recalculated his conditional‑release expiration date, refusing to credit time spent incarcerated for supervised‑release violations.
In 2013 Schnagl filed a motion to correct his sentence under Minn. R. Crim. P. 27.03, subd. 9, seeking credit against his conditional‑release term for time in custody.
The State argued the district court lacked jurisdiction under Rule 27.03 because that rule challenges the legality of the court’s original sentence, not administrative implementation by the DOC; the State said habeas corpus was the proper remedy.
The district court found jurisdiction under Rule 27.03 but denied relief on the merits; the court of appeals affirmed on the merits but held Rule 27.03 provided jurisdiction.
The Minnesota Supreme Court held Rule 27.03 is not the proper procedure to obtain judicial review of a DOC administrative decision implementing a sentence; habeas corpus is the appropriate vehicle. The denial was affirmed without reaching the merits.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a motion under Minn. R. Crim. P. 27.03, subd. 9, may be used to obtain judicial review of the DOC’s administrative decisions implementing a court‑imposed sentence	Schnagl: Rule 27.03 allows correction of an illegal extension of his conditional‑release term and thus authorizes relief	State/DOC: Rule 27.03 addresses only sentences as imposed by the court; administrative implementation is reviewed by habeas corpus and the DOC must be a party	Held: Rule 27.03 is not the proper procedure; habeas corpus (naming the DOC) is the correct vehicle for review
Whether Schnagl was entitled to credit against his conditional‑release term for time in custody on supervised‑release violations (statutory interpretation / merits)	Schnagl: Time incarcerated for supervised‑release violations must be deducted from the conditional‑release term under the applicable statute	State/DOC: Time for supervised‑release violations is not creditable against the conditional‑release term as administered by the DOC	Held: Court declined to reach the merits; denial of Rule 27.03 motion affirmed because wrong procedural vehicle

Steel Co. v. Citizens for a Better Env’t, 523 U.S. 83 (jurisdictional principles)
Giersdorf v. A & M Constr., Inc., 820 N.W.2d 16 (Minn. 2012) (definition of subject matter jurisdiction)
State v. Shattuck, 704 N.W.2d 131 (Minn. 2005) (district court authority over imposition of sentence)
State v. Garcia, 582 N.W.2d 879 (Minn. 1998) (use of Rule 27.03 to correct an originally unauthorized sentence)
State v. Humes, 581 N.W.2d 317 (Minn. 1998) (same)
State v. Schwartz, 628 N.W.2d 134 (Minn. 2001) (recognizing habeas as vehicle to review post‑sentence administrative release decisions)