Supreme Court Digest: May 27, 2026

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Criminal

Prior Convictions

Review

Petitioner was charged with felony domestic assault in violation of Minn. Stat. § 609.2242, subd. 4. Domestic assault under this statute is a felony-level offense if the defendant also has two or more previous domestic violence-related convictions within the past ten years. Although petitioner did not personally waive his right to a jury trial on the prior-convictions element, his trial counsel stipulated to petitioner’s prior convictions. As a result, the jury was not asked to determine whether the State had proven the prior-convictions element. The jury found petitioner guilty of domestic assault. Petitioner petitioned for postconviction relief on the ground that the State failed to prove the prior-convictions element. The postconviction court vacated petitioner’s conviction on that ground. The State moved for reconsideration, claiming trial error, and the postconviction court, after reconsidering the matter, reinstated petitioner’s conviction. The Court of Appeals affirmed.

The Supreme Court held that (1) the District Court’s reinstatement of petitioner’s conviction did not violate the Double Jeopardy Clauses of the Minnesota Constitution and United States Constitution because the reinstatement was not double prosecution or double punishment; and (2) when a defendant prevents the State from submitting substantive evidence to satisfy a prior-convictions element for a charged offense, the invited-error doctrine applies, and a court cannot grant relief unless failure to do so would seriously affect the fairness, integrity, or public reputation of judicial proceedings. Affirmed.

A23-1134 State v. Sullivan (Court of Appeals)