State v. Scovel, 916 N.W.2d 550

In 2007 Scovel pleaded guilty to fifth-degree possession (a felony at that time) and received a prison sentence exceeding one year.
In March 2016 Scovel committed the current offense (sale of a controlled substance); sentencing would occur months later.
Between commission and sentencing, the 2016 Drug Sentencing Reform Act (effective Aug. 1, 2016) reclassified some first-time fifth‑degree possession offenses from felonies to gross misdemeanors for certain amounts.
At sentencing in September 2016 the district court counted Scovel’s 2007 conviction as a felony for criminal-history scoring, resulting in a criminal-history score that produced a 70‑month presumptive sentence.
On appeal Scovel argued the 2007 conviction should be treated as a gross misdemeanor (because of the DSRA in effect at sentencing) and thus not yield felony criminal‑history points; the court of appeals affirmed the district court.
The Minnesota Supreme Court granted review to decide whether Guidelines 2.B.7.a’s use of “current Minnesota offense definitions ... and sentencing policies” refers to the law at the time the current offense was committed or at the time of sentencing.

Issue	Scovel's Argument	State's Argument	Held
Whether "current Minnesota offense definitions...and sentencing policies" in Minn. Sent. Guidelines 2.B.7.a means definitions in effect at sentencing or at commission of the current offense	"Current" means at time of sentencing; Scovel's 2007 felony was reclassified by the DSRA before sentencing and thus should not count as felony points	"Current" means at time the current (March 2016) offense was committed; the 2007 conviction was a felony when the current offense occurred and qualifies for felony points	Court held "current" means the definitions in effect when the current Minnesota offense was committed (not at time of sentencing); Scovel properly received felony criminal-history points

State v. Williams, 771 N.W.2d 514 (Minn. 2009) (criminal-history points for prior felony convictions explained)
State v. Washington, 908 N.W.2d 601 (Minn. 2018) (Guidelines interpretation reviewed de novo)
State v. Campbell, 814 N.W.2d 1 (Minn. 2012) (plain and ambiguous Guidelines language and when to consult other aids)
State v. Jones, 848 N.W.2d 528 (Minn. 2014) (construing potentially conflicting Guidelines provisions to give effect to both)
State v. Shattuck, 704 N.W.2d 131 (Minn. 2005) (sentencing objectives: uniformity, proportionality, predictability)
State v. Maurstad, 733 N.W.2d 141 (Minn. 2007) (sentences must be based on correct criminal-history scores to ensure equal sanctions)