Significant Minnesota Blakely opinion

Last week, the recent Minnesota Supreme Court issued an interesting and important ruling in State v. Barker, No. A04-1453 (Minn. Nov. 17, 2005) (available here).  Previously discussed here following a March ruling by the state Court of Appeals, Barker raised the issue of whether the US Supreme Court’s Harris decision, which allows for judicial fact-finding in support of mandatory minimums, might permit such fact-finding when the mandatory minimum sentence is greater than the presumptive guideline sentence. 

The Minnesota Supreme Court decision in Barker reaffirms that imposition of a higher “mandatory minimum sentence” sentence still violates Blakely when based on facts not found by a jury.  (In other words, Blakely trumps Harris when they are in tension.)  The Barker case also covers some important ground concerning the meaning of what it calls “the Blakely admission exception.”