State of Minnesota v. Nicholas David Butze

Citations

• 9 N.W.3d 582

Syllabus

In a prosecution for driving after suspension of driving privileges, the admission of a Minnesota Department of Public Safety \certificate of order sent\ that is created after the prosecution has begun for the purpose of proving the element that the defendant was served notice of the suspension by mail violates a criminal defendant's Sixth Amendment right to confrontation to the extent that the certificate of order sent contains information about mailing that is not in the underlying notice of suspension or other nontestimonial agency record. Reversed and remanded.