State of Minnesota v. Jaye William Snyder

Syllabus

1. The United States Supreme Court decisions in Apprendi v. New Jersey, 530 U.S. 466 (2000), and Blakely v. Washington, 542 U.S. 296 (2004), do not call into question the analysis in State v. Ronquist, 600 N.W.2d 444 (Minn. 1999), which limited the indictment requirement of Minnesota Rule of Criminal Procedure 17.01, subdivision 1, 1 to offenses punishable by life imprisonment before a sentencing enhancement based on a prior conviction is applied. 2. The reasoning in Ronquist applies with equal force to a conditional release, and the discretion given to the Department of Corrections in fashioning conditions of release does not compel a different result because any due process concerns regarding the uncertainty of a release condition can be addressed when the condition is imposed. Affirmed.