835 N.W.2d 24
Minn. Ct. App.2013Background
- Brown was charged in Ramsey County (March 2010) with third-degree criminal sexual conduct after an alleged May 2009 incident.
- He pleaded guilty in June 2010; a sentencing hearing was scheduled for August 2010, but Brown did not appear.
- While imprisoned for a separate Hennepin County offense, Brown received a detainer-related memorandum and later a letter concerning his sentence.
- A 2011 notice mischaracterized Brown’s Ramsey County charge as untried and his right to final disposition as 180 days; Brown did not sign the form.
- In April 2012, Brown moved to dismiss the Ramsey County charge on UMDDA grounds; sentencing occurred later that month, and Brown was sentenced to 120 months.
- The issue is whether UMDDA requires dismissal when sentencing is delayed after a guilty plea and a detainer request.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether UMDDA requires dismissal for sentencing delay | Brown argues for dismissal under §629.292 | State argues dismissal only if guilt trial is not within six months | No dismissal for sentencing delay; only guilt/innocence trial within six months triggers dismissal |
Key Cases Cited
- State v. Miller, 525 N.W.2d 576 (Minn.App.1994) (UMDDA purpose to provide speedy disposition of untried charges)
- State v. Vonbehren, 777 N.W.2d 48 (Minn.App.2010) (UMDDA goals for prisoners facing additional charges)
- Carchman v. Nash, 473 U.S. 716 (U.S. 1985) (IAD/UMDDA detainer relief aims to prevent detainers from being baseless)
- State v. Lewis, 422 N.W.2d 768 (Minn.App.1988) (IAD interpretation: trial does not include sentencing)
- Pollard v. United States, 352 U.S. 354 (U.S. 1957) ( Sixth Amendment speedy trial discussion; context for trial vs. sentencing)
- State v. Cross, 771 N.W.2d 879 (Minn.App.2009) (Sixth Amendment/public trial context; sentencing relevance)
- Wilson, 632 N.W.2d 225 (Minn.2001) (UMDDA/IAD interpretation guidance)