State v. Strobel

Summary

The Minnesota Supreme Court considered whether the classification of a prior offense under Minnesota Sentencing Guidelines § 2.B.7.a is determined by the statute defining the offense or by general statutory definitions of felony and gross misdemeanor. The court held that “current Minnesota offense definitions” refers to the element-based definitions of crimes. It affirmed the court of appeals’ reversal of the sentence and remand for resentencing because the State had not established that Strobel’s prior controlled-substance-possession offense qualified as a felony.

Holdings

1. The phrase "current Minnesota offense definitions" in section 2.B.7.a refers to the element-based statutory definitions of crimes, rather than merely to the categorical felony and gross-misdemeanor definitions in Minn. Stat. § 609.02.
2. The State did not establish that Strobel's 2012 fifth-degree possession conviction qualified as a felony under the element-based offense definitions applicable under section 2.B.7.a; therefore, the court of appeals properly reversed the sentence and remanded for resentencing.

Questions Presented

1. Under Minnesota Sentencing Guidelines section 2.B.7.a, is the classification of a prior offense determined by the statute defining the elements of the crime or by Minn. Stat. § 609.02's categorical definitions of felony and gross misdemeanor?
2. Did the State prove that Strobel's 2012 fifth-degree possession conviction qualified as a felony for purposes of calculating his criminal-history score?

Disposition

affirmed