January 22, 2024, Minnesota Court of Appeals Update:
The Minnesota Court of Appeals released one precedential opinion:
In re Welfare of M.A.B., A23-0752 (Minn. App. Jan. 22, 2024),
Today, the Minnesota Court of Appeals concluded in a precedential opinion that district courts retain subject matter jurisdiction to terminate a continuance for dismissal (CFD) after a juvenile turns 19 years old.
The court of appeals rejected the appellant’s argument that the district court lacked subject-matter jurisdiction to adjudicate him delinquent of fifth-degree criminal sexual conduct because the court terminated the CFD after he turned 19 years old.
The court concluded that when the State moves to terminate a CFD within the time frame specified under Minnesota Rule of Juvenile Delinquent Procedure 14.04, the district court retains subject-matter jurisdiction over an adult defendant’s termination hearing under Minnesota Statutes section 260B.193, subdivision 5(c), to “conduct a trial” until the defendant turns 21 years old.
Ordinarily, section 260B.193 terminates a district court’s juvenile jurisdiction when the juvenile turns 19. The exception to the rule is that a “trial” can be conducted until the juvenile turns 21 years old. Minn. Stat. § 260B.193, subdivision 5(c). In this case, the court equated a CFD termination hearing to a “trial” and concluded that a CFD termination hearing falls within the exception and district courts therefore retain juvenile jurisdiction until the juvenile turns 21.
Court of Appeals Opinion (mncourts.gov)
The Minnesota Court of Appeals also released a notable non-precedential opinion
State v. Robinson, A23-0251 (Minn. App. Jan. 22, 2024)
The Minnesota Court of Appeals relied on the Minnesota Supreme Court’s recent decision in State v. Torgerson, 995 N.W.2d 164 (Minn. 2023), and reversed the district court’s finding that law enforcement had probable cause to search Robinson’s vehicle without a warrant. The court of appeals concluded that, “because the odor of marijuana alone could not support probable cause for law enforcement to search Robinson’s vehicle, the district court erred in denying Robinson’s motion to suppress and to dismiss on that basis.” The court of appeals also rejected the State’s argument that the good faith exception applied.
