More Minnesota remands
As discussed here and here, the Minnesota Sentencing Guidelines Commission’s “short-term report” about Blakely sought to downplay the overall impact of Blakely on Minnesota state sentencing. And though it may be true that neither Minnesota nor any other state will experience the dramatic disruptions occurring in the federal system, the now regular pattern of Blakely remands from the state intermediate courts in Minnesota reveals that even “small” Blakely disruptions are still disruptive to the regularized administration of justice.
Thus, today we get standard remands in three Minnesota state cases. See State v. Lenear, 2004 WL 1878770 (Minn. App. Aug. 24, 2004); State v. Juenke, 2004 WL 1878797 (Minn. App. Aug. 24, 2004); State v. Krueger, 2004 WL 1878998 (Minn. App., Aug. 24, 2004). There is nothing uniquely consequential about any of these remands, though I could not help but notice that all three cases involved sex offenses and Lenear involved a “quadruple upward durational departure”!