State of Minnesota v. Jesse Tyler Schafer, A16-1156

Background

In 2013, 17-year-old Jesse Schafer had sexual intercourse with a 14-year-old; juvenile court certified the case to adult court and the state charged third-degree criminal sexual conduct.
Schafer pleaded guilty in 2014; the district court stayed adjudication for four years and imposed probation with conditions including: no alcohol/controlled substances, filtered computers/phones, no unsupervised contact with females under 16 (supervised contact required agent approval), and no pornographic material.
Schafer repeatedly violated probation (drug use, pornography, unfiltered/unauthorized cell phones, Facebook access), leading to multiple admits and contested violation proceedings.
At a contested April 2016 probation-violation hearing, the district court found Schafer violated several conditions, concluded violations were serious and related to the underlying offense, revoked the stay, and executed a 36-month sentence.
On appeal Schafer argued: (1) adult court lacked subject-matter jurisdiction because juvenile certification was invalid; (2) he did not violate the supervision condition as his contact with minors was adult-supervised; and (3) evidence was insufficient to show confinement was warranted over continued probation.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Jurisdiction — validity of juvenile certification	State: certification (including waiver/stipulation) conferred jurisdiction	Schafer: certification invalid because based on waiver/plea agreement, not public-safety findings	Court: record lacked full juvenile documents but addendum showed a valid waiver/stipulation-style order; Schafer would not prevail
Whether Schafer violated supervised-contact condition	State: phone photos and files showed contact with females under 16 and porn, and agent approval was required before any supervised contact	Schafer: adult girlfriend supervised contact with her children, so condition was satisfied; written terms didn’t clearly require agent approval for supervised contact	Court: probation terms and court statements (and Schafer’s own behavior) showed he knew agent approval was required; no due-process violation
Due process — fair notice of probation terms	State: court explained condition at sentencing and agreements were signed repeatedly	Schafer: language ambiguous; mixed messages from court deprived him of fair warning	Court: record shows clear notice (court statements, repeated agreements, prior requests for approval); due process satisfied
Sufficiency for revocation — need for confinement vs. probation policy	State: repeated, serious, offense-related violations justified confinement to protect public and rehabilitate	Schafer: revocation was excessive; policies favor probation and rehabilitation	Court: record supported that confinement was necessary to protect public/ensure treatment; revocation not an abuse of discretion

Key Cases Cited

In re Welfare of J.H., 844 N.W.2d 28 (Minn. 2014) (standard of review for juvenile certification decisions)
State v. Modtland, 695 N.W.2d 602 (Minn. 2005) (requirements for revoking probation and balancing confinement against probation policy)
State v. Austin, 295 N.W.2d 246 (Minn. 1980) (probation revocation standards)
State v. Ornelas, 675 N.W.2d 74 (Minn. 2004) (district court discretion in probation revocation)
State v. Beaulieu, 859 N.W.2d 275 (Minn. 2015) (de novo review for due-process claims on sentencing/probation notice)
State v. Rottelo, 798 N.W.2d 92 (Minn. App. 2011) (probation revocation where pattern of noncompliance and lack of supervision contact supported revocation)