State v. Campbell
2012 Minn. LEXIS 182
Minn.2012Background
- Campbell was convicted of six offenses including gross misdemeanor driving after cancellation and felony fleeing resulting in death.
- The district court sentenced 12 months for the gross misdemeanor and 234 months for the felony, using a criminal history score of three.
- The court of appeals reversed, and this court granted review to reinstate the district court’s sentence.
- The central issue is how to calculate the presumptive duration for a permissive consecutive felony sentence when paired with a gross misdemeanor.
- The court ultimately held that “another offense” in 2.F.2. refers to a felony offense, and Campbell’s three-point history was properly used in determining the duration; the total sentence is reinstated.
- Campbell also challenged the inclusion of one criminal history point for a 1995 robbery stayed sentence; the court held that felony stays of imposition count for criminal history.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Meaning of ‘another offense’ in 2.F.2. | Campbell: ‘another offense’ means any offense; zero history. | State: ‘another offense’ means felony offense; zero history not required. | Ambiguous; interpreted as ‘another felony offense’; three points used; sentence reinstated. |
| Criminal history point for 1995 robbery stay. | Campbell: stay of imposition yields no felony history point. | State: stays of imposition count as felony history points under 2.B.1. | District court did not err; one felony history point properly counted. |
Key Cases Cited
- Christensen v. Hennepin Transp. Co., 215 Minn. 394 (1943) (interpret statutes in light of context)
- State v. Williams, 771 N.W.2d 514 (Minn. 2009) (statutory interpretation; de novo review of guidelines)
- State v. McGee, 347 N.W.2d 802 (Minn. 1984) (commission policy and official interpretation guidance)