Willie Edd Reynolds v. State of Minnesota
2016 Minn. App. LEXIS 5
| Minn. Ct. App. | 2016Background
- Willie Edd Reynolds pleaded guilty (2008) to failing to register as a predatory offender and was sentenced to 1 year and 1 day with a downward durational departure; no conditional-release term was imposed at that time.
- Three months after sentencing the district court, sua sponte and without a resentencing hearing, added a statutorily mandated 10-year conditional-release term, apparently finding Reynolds was a risk-level III offender.
- Four years later (2013) Reynolds moved to correct his sentence under Minn. R. Crim. P. 27.03, subd. 9, arguing the conditional-release term required either a jury finding or an admission under Blakely principles.
- The district court treated the motion as a postconviction petition and dismissed it as time-barred under Minn. Stat. § 590.01; it alternatively held no Sixth Amendment violation because the court may find risk level analogously to prior-conviction findings.
- The court of appeals considered whether Rule 27.03 is a proper vehicle for this Blakely challenge and whether the addition of the conditional-release term without a jury/admission violated the Sixth Amendment; it reversed and remanded.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Rule 27.03, subd. 9 is a proper vehicle for challenging the sua sponte addition of a conditional-release term. | Reynolds: Rule 27.03 permits correction of a sentence "not authorized by law," so his Blakely challenge fits and is not time-barred by the postconviction statute. | State: The statute-authorized conditional-release term was permitted by law; any Blakely problem is procedural and belongs in a postconviction petition subject to the 2-year limit. | Rule 27.03 is a proper mechanism; the challenge is not time-barred under the postconviction statute. |
| Whether imposing a 10-year conditional-release term based on judge-found risk-level III violated the Sixth Amendment under Blakely. | Reynolds: The court’s judicial finding of risk-level III (not admitted or found by a jury) increased his sentence and violated Blakely. | State: Risk-level status is like a prior conviction; courts can determine it without a jury, so no Blakely violation. | Applying State v. Her, the court held the judge’s unilateral finding violated the Sixth Amendment; the conditional-release term must be based on a jury finding or admission. |
| Proper remedy after finding a Blakely violation (resentencing, jury determination, or other). | Reynolds: Resentencing without allowing a sentencing jury now (argues double jeopardy risk). | State: District court has authority to impanel a sentencing jury on remand; double jeopardy does not bar retrospective jury determination. | Court did not prescribe a specific remedy; remanded to district court to determine appropriate remedy after argument. |
Key Cases Cited
- State v. Her, 862 N.W.2d 692 (Minn. 2015) (held that a judge may impose the 10-year conditional-release term only if risk-level III is admitted or found by a jury)
- Blakely v. Washington, 542 U.S. 296 (2004) (Sixth Amendment requires jury findings for facts that increase a sentence beyond the statutory maximum)
- State v. Chauvin, 723 N.W.2d 20 (Minn. 2006) (discusses Blakely as changing procedure for imposing aggravated sentences)
- State v. Hankerson, 723 N.W.2d 232 (Minn. 2006) (authorized retrospective use of a sentencing jury after a Blakely violation; double jeopardy discussion)
- United States v. Morgan, 346 U.S. 502 (1954) (federal precedent on correcting illegal sentences under an earlier version of Fed. R. Crim. P. 35)
- Hill v. United States, 368 U.S. 424 (1962) (clarified that correction of illegal sentence is narrow and distinct from collateral attack on trial errors)
- State v. Shattuck, 704 N.W.2d 131 (Minn. 2005) (explains sentencing guidelines presumptive range as the baseline for what a judge may impose without additional fact-finding)