State of Minnesota v. Rosalyn Mary Brooks, A16-153

Rosalyn Mary Brooks was charged and convicted by a jury of engaging in the business of concealing criminal proceeds for operating "Papa Dimitri’s" restaurant used to hide proceeds from her son Ryan’s marijuana sales.
Trial evidence showed Brooks ran day-to-day operations, signed checks, paid bills, handled the lease, and claimed co-ownership after cashing retirement savings to start the business.
Bank records: From Jan 2013–Nov 2014 about $207,796 was deposited into the restaurant account, while recorded sales were only a small fraction; many deposits were cash.
Surveillance and search-warrant evidence showed minimal legitimate business activity (low sales, limited hours, few customers), discovery of marijuana in mailed package to the restaurant address, and drugs/weapons at Brooks’s home (with Ryan’s DNA on a handgun).
Recorded jail call in which Brooks said she wanted out and Ryan warned her not to speak about the operation. District court stayed execution of sentence, placed Brooks on probation up to ten years, and ordered 60 days in jail.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence to prove Brooks knew the restaurant concealed drug proceeds	State: Circumstantial evidence (bank deposits, Brooks’s management role, surveillance, postal/package seizure, jail call) supports knowledge beyond reasonable doubt	Brooks: No direct evidence she knew deposits were drug proceeds; could believe business deficits were explained by lawful means	Court: Evidence sufficient; circumstantial proof supports conviction when viewed favorably to jury
Proper severity-level assignment for an unranked offense	State: 20-year statutory max for "engaging in the business" implies a higher severity level (court assigned level 6)	Brooks: Conduct not sophisticated; argued for level 3 and pointed to lack of direct financial profit and single-transaction comparisons	Court: No abuse of discretion in assigning severity level 6 given statutory max, comparators, and gravity of ongoing concealment

State v. Webb, 440 N.W.2d 426 (discussing standard for reviewing sufficiency of evidence)
State v. Brocks, 587 N.W.2d 37 (court defers to jury credibility determinations)
Bernhardt v. State, 684 N.W.2d 465 (affirming standard that verdict stands if reasonable jurors could convict)
State v. Anderson, 789 N.W.2d 227 (two-step analysis for circumstantial-evidence sufficiency)
State v. Lahue, 585 N.W.2d 785 (alternative-hypothesis must be plausible and supported)
State v. Kenard, 606 N.W.2d 440 (legislative maximum sentences inform severity-level decisions)
State v. Huynh, 519 N.W.2d 191 (upholding higher severity level based on statutory penalty similarity)
State v. Bertsch, 707 N.W.2d 660 (appellate review of district court severity-level assignment is for abuse of discretion)