State v. Leathers
2011 Minn. LEXIS 393
| Minn. | 2011Background
- Leathers was convicted of five counts of first-degree assault against peace officers under Minn. Stat. § 609.221, subd. 2(a).
- The district court sentenced him to 189 months with eligibility for supervised release after 126 months, and ordered concurrent terms.
- The court of appeals reversed the sentence but upheld the conviction; this Court granted review on the supervised-release issue.
- The issue concerns whether § 609.221, subd. 2(b) bars supervision until the full term of imprisonment is served.
- There is a statutory ambiguity about what constitutes the “full term of imprisonment” for purposes of § 609.221, subd. 2(b).
- The Court ultimately holds that the “full term of imprisonment” means two-thirds of the executed sentence, making Leathers ineligible for supervised release until that portion is served.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does §609.221(2)(b) bar supervised release before two-thirds of the sentence is served? | Leathers advocates two-thirds interpretation. | State argues full-term interpretation; no partial eligibility. | Ambiguity exists; two-thirds interpretation adopted. |
| What is the proper interpretive framework to resolve the ambiguity? | Use plain meaning or two-thirds framework. | Prefer statutory interplay with chapter 244; limit reliance on 244.01. | Apply canons of in pari materia and lenity; two-thirds interpretation favored. |
| What is the court’s final interpretation of “full term of imprisonment” in §609.221(2)(b)? | Two-thirds of executed sentence. | Whole term in prison. | “Full term of imprisonment” means two-thirds of the executed sentence. |
Key Cases Cited
- Minn. v. Bluhm, 676 N.W.2d 649 (Minn. 2004) (statutory interpretation where plain language guides ambiguity)
- Amaral v. Saint Cloud Hosp., 598 N.W.2d 379 (Minn. 1999) (ambiguity resolved in favor of defendant when criminal statute unclear)
- State v. Niska, 514 N.W.2d 260 (Minn. 1994) (lenity principle in criminal statutes)
- Meister v. W. Nat. Mut. Ins. Co., 479 N.W.2d 372 (Minn. 1992) (statutory interpretation with knowledge of prior legislation)
- State v. Maurstad, 733 N.W.2d 141 (Minn. 2007) (lenity and narrow construction of ambiguous criminal language)
- State v. Lubitz, 472 N.W.2d 131 (Minn. 1991) (minimally construe minimum term statutes against the State)
- Vickla v. State, 793 N.W.2d 265 (Minn. 2011) (interrelation of chapter 244 and 609 governing sentences)
- State v. Edwards, 774 N.W.2d 596 (Minn. 2009) (noting interplay of 244 and 609 in sentencing)