State v. Barker

Summary

The Minnesota Supreme Court held that Minn. Stat. § 609.11 violated the Sixth Amendment to the extent it allowed a court, rather than a jury, to find sentencing factors supporting a mandatory minimum sentence beyond the presumptive guideline range. The court also held that statements made by the defendant after the erroneous denial of his request for a jury determination could not qualify under the Blakely admission exception. The court affirmed the court of appeals and remanded for sentencing within the presumptive range.

Holdings

1. Minn. Stat. § 609.11 is unconstitutional to the extent that it authorizes an upward durational departure beyond the presumptive guideline sentence based on a sentencing factor found by the district court without a jury determination or an otherwise valid admission by the defendant.
2. Statements made by a defendant after the defendant requested and was erroneously denied a jury determination of a fact necessary to enhance the sentence may not be used to satisfy the Blakely admission exception.
3. The court lacked authority to remand for impaneling a sentencing jury under Minn. Stat. § 609.11; the case must instead be remanded for imposition of a sentence within the presumptive guideline range.

Questions Presented

1. Whether Minn. Stat. § 609.11's mandatory-minimum firearm enhancement violated Barker's Sixth Amendment right to a jury trial when the sentencing factor was found by the district court rather than a jury.
2. Whether Barker's sworn admissions at a sentencing hearing held after the district court erroneously denied his request for a jury trial satisfied the Blakely admission exception.
3. Whether the district court could impanel a sentencing jury on remand to determine the firearm-related sentencing factors under Minn. Stat. § 609.11.

Disposition

affirmed_and_remanded