State of Minnesota v. Abigail Rae Trulson, A16-561

Background

Abigail Trulson, age 20, worked as an in-home personal-care aide and stole items from two vulnerable clients between April and May 2015; total loss $2,080.
Charged with felony theft (aggregate value $1,000–$5,000); pleaded guilty with no agreed sentence; state reserved argument for a presumptive felony guideline sentence.
Presumptive sentence: stayed prison term of 1 year and 1 day (felony). At sentencing Trulson sought a downward durational departure to a 365-day stayed sentence (gross misdemeanor).
District court granted the durational departure, citing Trulson’s age, first-offense status, amenability to probation, and drug addiction as reasons.
State appealed, arguing those justifications do not provide substantial and compelling offense-related reasons for a durational departure.

Issues

Issue	Plaintiff's Argument (State)	Defendant's Argument (Trulson)	Held
Whether district court properly granted a downward durational departure	Departure improper because stated reasons are offender-related, not offense-related, and thus cannot overcome guideline presumption	Drug addiction, youth, first-offense status, amenability to probation, remorse, and relatively low dollar amount justify shorter (gross misdemeanor) sentence	Reversed: durational departure unjustified; remand for imposition of presumptive guideline sentence
Whether Trulson’s drug addiction is an offense-related mitigating factor	Addiction is an offender-related motive and voluntary intoxication is excluded; not a valid basis for durational departure	Addiction affected nature of offense and diminished culpability/capacity for judgment	Rejected: addiction is offender-related; voluntary intoxication not a proper basis for durational departure
Whether remorse or low aggregate value supports durational departure	Remorse does not reduce durational sentence unless it relates to offense seriousness; $2,080 is not close to the low end of statutory range and aggravating facts exist	Remorse and relatively low value of stolen property justify lesser sentence	Rejected: remorse did not relate back to offense seriousness; value exceeded low-end comparator and victims’ vulnerability/aggravating facts made offense not less serious
Whether plea agreement was breached if sentence reversed	N/A — State contends plea preserved sentencing arguments; no agreed sentence so reversal does not void plea	Trulson contends ability to seek durational departure was part of plea benefit and reversal entitles her to withdraw plea	Rejected: plea contained no sentence promise; both parties received agreed-upon terms; plea stands

Key Cases Cited

State v. Soto, 855 N.W.2d 303 (Minn. 2014) (guidelines sentence presumed appropriate; departures require substantial and compelling reasons)
Dillon v. State, 781 N.W.2d 588 (Minn. App. 2010) (standard of review for departures; legal review of whether reasons are proper)
State v. Geller, 665 N.W.2d 514 (Minn. 2003) (trial court must state reasons for departure on record; reasons must be legally sound and record-supported)
State v. Bauerly, 520 N.W.2d 760 (Minn. App. 1994) (remorse and significantly lower property value can support durational departure in limited circumstances)
State v. Peter, 825 N.W.2d 126 (Minn. App. 2012) (offender-related factors cannot support durational departures)
State v. Behl, 573 N.W.2d 711 (Minn. App. 1998) (amenability to probation is not a basis for durational departure)
State v. Gardner, 328 N.W.2d 159 (Minn. 1983) (chemical dependency generally not a proper basis for durational departure)
State v. Trog, 323 N.W.2d 28 (Minn. 1982) (offender-related factors may support dispositional but not durational departures)
State v. Brown, 606 N.W.2d 670 (Minn. 2000) (plea-agreement enforcement evaluated by parties’ reasonable understanding)