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Criminal Procedure – Stipulated Facts Trial

In a stipulated-facts trial under Minn. R. Crim. P. 26.01, subd. 3, when a party stipulates to the admission of a criminal complaint without any restriction as to its use, the District Court may make factual findings to support its decision based on the factual portion of the probable-cause section of the complaint.

“We agree that a defendant may qualify his stipulation to the admission of the criminal complaint in a stipulated-facts trial for [the limited purpose of informing the court of the offenses with which the defendant has been charged]. But in this case, appellant did not object to, or otherwise qualify his stipulation as to how the complaint could be used.”

We also conclude that defendant’s sentence was not improperly affected by his out-of-court statements.


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