Adrian Dominic Riley v. State of Minnesota

Syllabus

1. The district court erred in concluding it lacked jurisdiction to hear appellant's motion to correct a sentence under Minnesota Rule of Criminal Procedure 27.03, subdivision 9, which only challenged the lawfulness of his mandatory life sentences, because under Reynolds v. State, 888 N.W.2d 125 (Minn. 2016), such a motion is not subject to the limitations period imposed by Minnesota Statutes § 590.01, subdivision 4, and even if it were, under Carlton v. State, 816 N.W.2d 590 (Minn. 2012), the limitations period imposed by Minnesota Statutes § 590.01, subdivision 4 is not jurisdictional. 2. Although the district court erred when it concluded that it lacked jurisdiction, it reached the correct outcome in this case because appellant was sentenced to statutorily mandated life sentences for first-degree murder, and therefore the absence of a presentence investigation, as well as the alleged miscalculation and improper weighing of his criminal history score, did not render his sentences unlawful within the meaning of Minnesota Rule of Criminal Procedure 27.03, subdivision 9 because the presentence investigation statute and the Minnesota Sentencing Guidelines do not govern mandatory life imprisonment sentences for first-degree murder. Affirmed.