Willie Edd Reynolds v. State of Minnesota, 888 N.W.2d 125

Reynolds pleaded guilty in 2008 to failing to register as a predatory offender and was sentenced to 1 year and 1 day; the district court later (sua sponte) added a 10-year conditional-release term.
Minnesota law mandates a 10-year conditional-release term for offenders who "were assigned to risk level III" at the time of the offense. The record contained no jury finding or admission that Reynolds was risk-level III.
More than four years after sentencing, Reynolds moved under Minn. R. Crim. P. 27.03, subd. 9, to correct a sentence "not authorized by law," arguing Blakely error (no jury/admission for the fact increasing punishment).
The district court treated the motion as a postconviction petition and dismissed it as untimely under the 2-year limitations period in Minn. Stat. § 590.01, subd. 4.
The court of appeals reversed, vacated the conditional-release term, and remanded; the State sought review. The Supreme Court affirms the court of appeals.

Issue	Plaintiff's Argument (Reynolds)	Defendant's Argument (State)	Held
Whether a Blakely-based challenge to a conditional-release term falls within Minn. R. Crim. P. 27.03, subd. 9 ("sentence not authorized by law").	The conditional-release term was unauthorized because no jury finding or admission supported the risk-level-III fact required for the 10-year term; Rule 27.03(9) allows correction "at any time."	The sentence is facially authorized by statute (and thus not outside Rule 27.03(9)) because the court could have imposed the term if proper procedures (jury/admission) had been followed.	Held: Falls within Rule 27.03(9). A sentence imposed without the required jury finding or admission is not "authorized by law."
Whether the exclusivity and 2-year limitations in Minn. Stat. § 590.01 require bringing this claim as a postconviction petition (thus time-barred).	Rule 27.03(9) permits correction "at any time"; the postconviction statute cannot displace a procedural court rule governing sentencing correction without violating separation of powers.	Minn. Stat. § 590.01, subd. 2 makes postconviction the exclusive remedy for collateral challenges to sentence and § 590.01, subd. 4 imposes a 2-year limit; thus the claim must be brought in postconviction and is untimely.	Held: Applying the 2-year postconviction limit to Rule 27.03(9) motions would unconstitutionally intrude on the judicial function (separation of powers). The limitations period does not apply to Rule 27.03(9) motions.

Blakely v. Washington, 542 U.S. 296 (2004) (Sixth Amendment requires jury finding or defendant admission for facts that increase prescribed sentence)
State v. Her, 862 N.W.2d 692 (Minn. 2015) (court lacks authority under Blakely to impose 10-year conditional-release term without jury finding or admission of risk-level III)
State v. Schnagl, 859 N.W.2d 297 (Minn. 2015) ("not authorized by law" means contrary to law or applicable statutes)
State v. Losh, 721 N.W.2d 886 (Minn. 2006) (statutory time limits that restrict court procedural authority can violate separation of powers)
Sanchez v. State, 816 N.W.2d 550 (Minn. 2012) (limitations in postconviction statute are substantive when challenging convictions and thus within legislative power)
State v. Fields, 416 N.W.2d 734 (Minn. 1987) (Rule 27.03(9) allows correction of illegal sentences via motion within the criminal case)
State v. Misquadace, 644 N.W.2d 65 (Minn. 2002) (imposition of sentence within statutory limits is a judicial function)