State of Minnesota v. Jaimiah Lamar Irby, 848 N.W.2d 515

Jaimiah Irby was tried twice (first trial mistrial June 2010; second trial June 2011) and convicted of multiple assault, burglary, and firearm-possession charges; both trials were presided over by Hennepin County District Judge Patricia Karasov.
After Irby’s convictions, the Minnesota Supreme Court, in In re Karasov, determined Karasov failed to reside in her judicial district from July 1 to September 30, 2009, and imposed discipline (censure and six‑month suspension without pay).
Irby argued Judge Karasov’s temporary absence created an automatic vacancy under Minn. Stat. § 351.02(4) (every office becomes vacant when the incumbent ceases to be an inhabitant of the district if the office is “local”), so she lacked authority to preside at his trial and he is entitled to a new trial.
The court of appeals rejected Irby’s claim and affirmed his convictions; the Minnesota Supreme Court granted review on whether § 351.02(4) rendered Karasov’s office vacant.
The Supreme Court held, by a majority, that a district court judgeship is not a “local” office within the meaning of § 351.02(4) and therefore the statute did not automatically vacate Karasov’s office; it affirmed the convictions. The opinion relied on statutory text, constitutional structure, and principles avoiding separation‑of‑powers conflict.

Issue	Plaintiff's Argument (Irby)	Defendant's Argument (State)	Held
Whether a district court judgeship is a "local" office under Minn. Stat. § 351.02(4)	§ 351.02(4) covers "every office," includes offices elected/appointed by district; Karasov ceased to be an inhabitant of her district, so her office became automatically vacant	District judges exercise statewide judicial power, are state officials; § 351.02(4)’s "local" qualifier excludes district judgeships	Held: District court judgeships are not "local" offices under § 351.02(4); statute does not vacate Karasov’s office and she had authority to preside.
Whether construing § 351.02(4) to cover district judges would raise an unresolved separation‑of‑powers problem requiring avoidance	Implicit: statute is self‑executing; vacancy follows residence change	Invoking constitutional concerns, the State argues removal/discipline of judges is governed by the judicial disciplinary framework and judicial/constitutional processes	Court applied constitutional‑avoidance canon (statute ambiguous) and adopted the construction avoiding a conflict: held unnecessary to decide whether § 351.02(4) is self‑executing or displaces judicial discipline.

In re Karasov, 805 N.W.2d 255 (Minn. 2011) (disciplinary proceeding finding Karasov failed to reside in her judicial district)
State v. Harris, 667 N.W.2d 911 (Minn. 2003) (plain‑error review inappropriate for fundamental judicial‑authority questions)
State v. Pflepsen, 590 N.W.2d 759 (Minn. 1999) (de novo review of lower court authority and jurisdiction)
In re Civil Commitment of Giem, 742 N.W.2d 422 (Minn. 2007) (statutory construction and application of constitutional‑avoidance canon)
Lundquist v. Leonard, 652 N.W.2d 33 (Minn. 2002) (legislature may treat offices elected within a place as state offices)
Clayton v. Kiffmeyer, 688 N.W.2d 117 (Minn. 2004) (judges appointed/elected from districts serve the entire state)