State v. Ali
2011 Minn. LEXIS 632
| Minn. | 2011Background
- Seward Market shootings in Minneapolis; three victims killed on Jan 6, 2010.
- Appellant Mahdi Hassan Ali indicted Feb 4, 2010 on three counts each of first-degree premeditated murder and first-degree murder in the course of a felony.
- Indictment alleged Ali born Jan 1, 1993, making him 17 and subject to district court jurisdiction.
- Ali moved to dismiss the indictment for lack of subject matter jurisdiction argue age meant juvenile court should govern.
- District court held State must prove Ali’s age by a preponderance of the evidence; Ali’s motion denied.
- Court of Appeals initially held the district court order nonappealable; this Court expedited review and affirmed the jurisdiction standard and age-proof standard.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether denial of motion to dismiss for lack of jurisdiction is appealable as of right | Ali: not listed in Rule 28.02(2)(2) | Ali: appealable under collateral/precedent logic | Yes; immediately appealable as of right. |
| What standard of proof governs distinguishing juvenile vs district court by age | Ali argues beyond a reasonable doubt is required | State argues preponderance of the evidence suffices | Preponderance of the evidence applies. |
Key Cases Cited
- Hunt v. Nevada State Bank, 285 Minn. 77 (1969) (denial of lack-of-jurisdiction dismissal is appealable as of right)
- Anderson v. City of Hopkins, 393 N.W.2d 363 (Minn. 1986) (summary judgment/qualified immunity; appealability)
- McGowan v. Our Savior’s Lutheran Church, 527 N.W.2d 830 (Minn. 1995) (appealability of pretrial orders based on governmental immunity or lack of subject matter jurisdiction)
- Kastner v. Star Trails Ass’n, 646 N.W.2d 235 (Minn. 2002) (collateral order doctrine adopted in civil cases; supports extension to criminal)