State v. Wakefield
1978 Minn. LEXIS 1391, 263 N.W.2d 76 (1978)
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Rule of Law:
When a state court imposes a sentence of imprisonment after a federal court has already sentenced the same defendant, and the state court does not explicitly specify whether the sentences are to run concurrently or consecutively, the state sentence is presumed to run concurrently with the federal sentence.
Facts:
- Robinson was involved in an aggravated robbery.
- Eyewitnesses to the robbery described the perpetrator as having a bruise or mark under his eye.
- Two drug agents, who had bought drugs from Robinson on the day of the robbery, testified they did not recall seeing any bruises on Robinson’s face.
- Four witnesses positively identified Robinson as the robber: two from the specific aggravated robbery in question, and two from a separate robbery committed the following day by the same individual.
- Robinson had a previously imposed sentence from a federal court.
- A state court subsequently imposed a sentence on Robinson for the aggravated robbery.
- The state trial court did not specify whether the state sentence should run concurrently or consecutively with the previously imposed federal sentence.
Procedural Posture:
- Robinson was found guilty by a district court jury of a charge of aggravated robbery.
- The trial court sentenced Robinson to a term of 3 to 20 years in prison.
- Robinson appealed the judgment of conviction to the Supreme Court of Minnesota.
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Issue:
Does a state sentence imposed after a federal sentence, without specific determination by the state trial court regarding concurrent or consecutive service, presume to run concurrently with the federal sentence?
Opinions:
Majority - PER CURIAM.
Yes, a state sentence imposed after a federal sentence, without specific determination by the state trial court, must be presumed to run concurrently with the federal sentence. The court affirmed Robinson's conviction, finding that the identification evidence was sufficient despite minor discrepancies. The court held that the exclusion of polygraph test results was proper, reaffirming its longstanding rule against their admissibility, as established in State v. Hill. Regarding the sentencing issue, the court distinguished its prior decision in State v. Peterson, which held that a state sentence imposed before a federal sentence would be presumed consecutive if not specified. Here, the sequence was reversed, with the state sentence following the federal sentence. The court found this situation aligned with the philosophy of Minn. St. 609.15, subd. 1, which states that if a court does not specify, sentences shall run concurrently, even though this statute technically applies only to sentences imposed by Minnesota courts. The court also noted consistency with the ABA Standards, which favor serving multiple sentences at one time under one correctional authority. The court concluded that the problem of ambiguity in sentencing would now be avoided by Rule 27.03, subd. 4, Rules of Criminal Procedure, which requires district courts to state the “precise terms of the sentence.”
Analysis:
This case clarifies the presumptive relationship between state and federal sentences when the state sentence is imposed second and the court is silent on concurrent/consecutive terms, reversing the Peterson presumption for this specific sequence. It reinforces the importance of judicial clarity in sentencing, pushing trial courts to explicitly state sentencing terms to avoid ambiguity. The decision promotes judicial economy and consistency with the policy that favors integrated correctional management of a defendant's total sentence, especially when offenses are prosecuted in different jurisdictions.
