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339 N.W.2d 263

Escobedo v. Oleisky

Supreme Court of Minnesota

Decided October 19, 1983

Supreme Court of Minnesota · decided 1983-10-19

Key passage — most relied on by later courts

“for all the time spent in custody in connection with the offense or behavioral incident for which sentence is imposed.”

quoted by 1 later decision, including Ex Parte Green

Relies on 58 Mich. App. 9 - People v. Ervin Thomas · State v. DaFonseca

Good law ✅— No negative treatment on recordhow we know

Decided 1983-10-19

How this case has been cited

Cited by 5 later decisions — most recently May 2019

5 state decisions

201983199020002010decided

Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.

View the full empirical analysis of this case →

AMDAHL, Chief Justice.

¶1 This is a petition for a writ of mandamus. Petitioner is a juvenile who was certified for prosecution as an adult on charges of criminal damage to property and trespass to a motor vehicle. Petitioner pleaded guilty to the charges and was sentenced by the trial court to consecutive jail terms of 90 days for each offense. The trial court refused to give petitioner credit for time spent in the juvenile detention center awaiting certification for prosecution as an adult. Minn.R.Crim.P. 27.03, subd. 4(b), provides credit for “all time spent in custody in connection with the offense or behavioral incident for which sentence is imposed ….” Petitioner has provided us with cases from two other jurisdictions holding that credit should be given in such a situation. State v. DaFonseca, 109 R.I. 414, 286 A.2d 592 (1972); People v. Thomas, 58 Mich.App. 9, 226 N.W.2d 734 (1975). The state has failed to provide us with an adequate reason why the Minnesota rule should not be interpreted similarly. We hold that the trial court erred in refusing to give petitioner credit for time spent in the detention center awaiting certification.

¶2 Remanded.

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