Riley v. Minnesota: Rule 27.03 Motions Are Not Time-Barred and PSIs/Sentencing Guidelines Do Not Control Mandatory Life Sentences

Introduction

In Adrian Dominic Riley v. State of Minnesota, the Minnesota Supreme Court addressed two recurring questions at the intersection of postconviction procedure and sentencing law:

Whether a district court has jurisdiction to hear a motion to correct an unlawful sentence under Minnesota Rule of Criminal Procedure 27.03, subdivision 9, when the defendant challenges only the lawfulness of his sentence; and
Whether the lack of a presentence investigation (PSI) and alleged errors in calculating a criminal history score can render unlawful a set of statutorily mandated life sentences for first-degree murder, including when those sentences are imposed to run consecutively.

Riley, convicted by a Carver County jury in 1996 of three counts of first-degree murder and three counts of second-degree murder stemming from a 1995 triple homicide, received three consecutive mandatory life sentences. After multiple unsuccessful postconviction efforts, Riley filed a 2024 motion under Rule 27.03, subdivision 9, asserting that (1) the absence of a PSI deprived the sentencing court of key mitigating information (dyslexia and a history of childhood physical abuse), and (2) the district court improperly used or weighed a criminal history score, leading to consecutive rather than concurrent sentences. The district court denied the motion for lack of jurisdiction.

On appeal, the Supreme Court clarified the proper characterization and review of such motions and ultimately affirmed the denial of relief on the merits.

Summary of the Opinion

Jurisdiction and characterization: The district court erred by treating Riley’s Rule 27.03 motion as a Minnesota Statutes chapter 590 postconviction petition and by concluding it lacked jurisdiction. Under Reynolds v. State, Rule 27.03 motions to correct an unlawful sentence are not subject to the two-year limitations period in Minn. Stat. § 590.01, subd. 4, and under Carlton v. State, even if the limitations period applied, it is not jurisdictional.
Merits: The Court affirmed the denial of relief because Riley’s sentences were not unlawful. Mandatory life sentences for first-degree murder are governed by statute, not by the PSI statute or the Minnesota Sentencing Guidelines. Thus, neither the absence of a PSI nor any alleged miscalculation or weighing of a criminal history score made the sentences “not authorized by law.”
Consecutive life sentences: Imposition of consecutive life sentences for multiple murders is permissible under Minnesota law and longstanding precedent, provided the sentences do not exaggerate the defendant’s criminality.
Prosecutor-initiated adjustments: Minn. Stat. § 609.133 did not provide a basis for relief because only the prosecutor may commence a sentence-adjustment proceeding under that statute, and the State did not do so.
Procedural admonition: The Court criticized the district court’s unexplained jurisdictional denial and reiterated the importance of providing reasoned orders to facilitate appellate review and inform the parties.

Analysis

Precedents Cited and Their Influence

Reynolds v. State, 888 N.W.2d 125 (Minn. 2016): The Court relied on Reynolds to reaffirm separation-of-powers limits on the postconviction statute’s reach. To the extent Minn. Stat. § 590.01, subd. 4 (the two-year limitations period), would restrict a Rule 27.03, subd. 9 motion (which by rule is correctable “at any time”), the statute must yield to the court-promulgated rule. This directly refuted the State’s position and the district court’s jurisdictional ruling.
Carlton v. State, 816 N.W.2d 590 (Minn. 2012): The Court emphasized that even within Chapter 590 practice, the two-year time bar is not jurisdictional. Thus, the district court’s statement that it “lacked jurisdiction” because of time limitations was legally incorrect.
State v. Maurstad, 733 N.W.2d 141 (Minn. 2007): Cited for the proposition that illegal sentences can be corrected “at any time,” underscoring the ongoing availability of Rule 27.03 relief for sentences contrary to law.
State v. Coles, 862 N.W.2d 477 (Minn. 2015): Guided the characterization inquiry: courts “look to the pleadings and the relief sought” to decide whether a filing is a Rule 27.03 motion or a Chapter 590 petition. Because Riley challenged only his sentence and did not seek relief that would implicate other issues (such as the validity of his conviction or plea), his filing properly fell within Rule 27.03.
State v. Schnagl, 859 N.W.2d 297 (Minn. 2015) and State v. Meger, 901 N.W.2d 418 (Minn. 2017): Provided the governing test for a Rule 27.03 correction: a sentence must be “contrary to law or applicable statutes,” and illegality is judged at the time of sentencing.
Hannon v. State, 957 N.W.2d 425 (Minn. 2021): Allocated the burden: a defendant bears the burden to prove the facts necessary to show a sentence was unauthorized by law.
State v. Walker, 235 N.W.2d 810 (Minn. 1975): Clarified PSIs are not an absolute right; the PSI statute does not mandate a PSI in every case. This undercut Riley’s claim that the absence of a PSI rendered his mandatory life sentences unlawful.
Sentencing Guidelines exclusions (1995 and 2024): The Court referenced the Minnesota Sentencing Guidelines’ longstanding exclusion of mandatory life sentences for first-degree murder from guideline control (1995: Guidelines II.E; current: 2.E(4)), confirming that criminal history scores are irrelevant to those sentences.
State v. Brom, 463 N.W.2d 758 (Minn. 1990); State v. Cole, 542 N.W.2d 43 (Minn. 1996); State v. Warren, 592 N.W.2d 440 (Minn. 1999): These cases authorize consecutive sentences for multiple victims so long as the aggregate sentence does not exaggerate the criminality of the conduct. They supported the lawfulness of Riley’s consecutive life terms for three murders.
Sanders v. State, 23 N.W.3d 86 (Minn. 2025): Reinforced that criminal history scores are irrelevant when a defendant receives mandatory life sentences.
Wayne v. State, 870 N.W.2d 389 (Minn. 2015); Johnson v. State, 877 N.W.2d 776 (Minn. 2016); Bolstad v. State, 966 N.W.2d 239 (Minn. 2021): The Court again declined to adopt a definitive standard of review for recharacterization decisions because the outcome here was the same under either de novo or abuse-of-discretion review.
Waiters v. State, 14 N.W.3d 279 (Minn. 2024); Scruggs v. State, 484 N.W.2d 24 (Minn. 1992); Bode v. DNR, 612 N.W.2d 862 (Minn. 2000); State v. Faber, 343 N.W.2d 659 (Minn. 1984): These decisions framed the remand-versus-resolution question. The Court resolved the merits in the interest of judicial economy because the record yielded an “obvious answer,” while admonishing district courts to state reasons in future orders.

Legal Reasoning

Characterizing the filing: The Court examined “the pleadings and the relief sought” and found Riley’s motion attacked only the lawfulness of his sentence—classic Rule 27.03 territory. There was no challenge to his conviction and no requested relief that would disturb plea agreements or otherwise exceed the Rule’s scope.
Jurisdiction and time limits:
- Under Rule 27.03, subd. 9, a court “may at any time” correct an unlawful sentence.
- The separation-of-powers holding in Reynolds bars the Chapter 590 limitations period from constraining Rule 27.03 motions.
- Even if Chapter 590 applied, Carlton makes clear the time bar is nonjurisdictional; thus, the district court’s “lack of jurisdiction” ruling was incorrect.
Standard for unlawful sentences: A sentence is unauthorized only if “contrary to law or applicable statutes,” and the illegality must exist at the time of imposition. The defendant bears the burden to show that illegality.
PSI claim fails:
- Although Minn. Stat. § 609.115 addresses presentence investigations, Minnesota law does not confer an absolute right to a PSI. Walker confirms that a PSI need not be conducted in every case.
- Here, the sentencing was controlled by Minn. Stat. § 609.185, which mandated life imprisonment for first-degree murder in 1996 (and still does). A PSI would not alter the statutory mandate.
- Therefore, the absence of a PSI did not render the sentences unlawful under Rule 27.03.
Criminal history score claim fails:
- Mandatory life sentences for first-degree murder are excluded from guideline control—both at the time of Riley’s sentencing and today. As such, criminal history scores neither drive the sentence length nor govern the permissibility of consecutive terms in this context.
- The State’s sentencing memorandum relied on multiple-victim consecutive sentencing cases, not on criminal history scores, underscoring the irrelevance of the Guidelines here.
Consecutive life sentences are lawful:
- For multiple victims, Minnesota courts have long affirmed consecutive sentences when they do not exaggerate the defendant’s criminality (Brom, Cole, Warren).
- Riley’s three consecutive life sentences for three murders comport with this doctrine.
Prosecutor-initiated adjustments inapplicable: Minn. Stat. § 609.133 authorizes the prosecutor to initiate sentence adjustments. Because the State did not commence such a proceeding, the statute afforded Riley no relief.
Disposition without remand: Although the district court provided no reasoning, the Supreme Court decided the merits in the interest of judicial economy because the record clearly showed the sentences were not unlawful.

Impact

Procedural clarity for Rule 27.03 motions: The decision reaffirms that defendants may bring Rule 27.03, subd. 9 motions “at any time” when challenging only the lawfulness of their sentences. District courts should not recharacterize such motions as Chapter 590 petitions merely to impose the two-year limitations period. This ensures continued access to a narrow but crucial avenue for correcting sentences that are contrary to law.
Jurisdictional errors avoided: District courts must not deny Rule 27.03 motions for “lack of jurisdiction” based on Chapter 590 timing. Even if Chapter 590’s time limits were relevant, they are nonjurisdictional. This decision should reduce erroneous dismissals and consequent appeals.
PSI and Guidelines boundaries for mandatory life: The opinion provides crisp guidance: for statutorily mandated life sentences for first-degree murder, the PSI statute and the Sentencing Guidelines do not control sentencing outcomes. Arguments premised on PSI omissions or criminal history scoring will not render such sentences unlawful.
Consecutive life terms for multiple murders: The Court’s reliance on long-settled precedent reinforces that multiple life sentences may be imposed consecutively for multiple victims so long as the aggregate sentence is commensurate with the defendant’s culpability. This preserves a consistent approach to the most serious violent crimes.
Sentencing adjustment pathway remains limited: The Court’s brief treatment of Minn. Stat. § 609.133 underscores that sentence-adjustment proceedings under that statute are initiated by prosecutors, not defendants or courts. Postconviction strategies must account for that structural limitation.
Reasoned orders are essential: The Court’s admonition that district courts must explain their reasoning may improve transparency, facilitate appellate review, and reduce unnecessary remands—promoting judicial economy.

Complex Concepts Simplified

Rule 27.03, subd. 9 (motion to correct a sentence): A procedural mechanism allowing a court to correct, at any time, a sentence that was unlawful when imposed—i.e., contrary to governing law or statutes.
Chapter 590 postconviction petitions: Broader collateral attacks on convictions and sentences, subject to a two-year filing window (with defined exceptions). Unlike Rule 27.03 motions, they address a wider array of claims beyond the bare lawfulness of the sentence.
Separation of powers (Reynolds): Court-made procedural rules (like Rule 27.03) cannot be curtailed by conflicting statutes. Thus, a statute’s time bar cannot negate a rule’s promise that unlawful sentences can be corrected “at any time.”
Nonjurisdictional time bar (Carlton): A deadline that limits relief but does not remove the court’s power to hear a case. A court does not “lose jurisdiction” merely because a filing is late under Chapter 590.
Presentence investigation (PSI): A report often prepared for the sentencing judge that may include a defendant’s background, criminal history, and other information. Minnesota law does not make PSIs mandatory in every case, and for mandatory life sentences, a PSI does not govern the sentencing outcome.
Mandatory life sentences for first-degree murder: Minn. Stat. § 609.185 mandates life imprisonment upon conviction; the Minnesota Sentencing Guidelines do not apply to the determination of sentence length for such offenses, and criminal history scores are irrelevant.
Consecutive vs. concurrent sentences: Concurrent sentences are served at the same time; consecutive sentences are served one after another. For violent crimes against multiple victims, Minnesota courts permit consecutive sentences so long as they do not exaggerate the criminality of the conduct.
Prosecutor-initiated sentence adjustments (Minn. Stat. § 609.133): A statutory mechanism that only prosecutors may initiate to adjust an already-imposed sentence in defined circumstances; defendants cannot invoke it unilaterally.

Conclusion

The Minnesota Supreme Court’s decision in Riley reinforces two core principles. First, a motion to correct an unlawful sentence under Rule 27.03, subd. 9 is a distinct, court-preserved remedy available “at any time,” unaffected by Chapter 590’s two-year limitations period and not subject to jurisdictional dismissal based on timing. Second, for statutorily mandated life sentences for first-degree murder, neither the PSI statute nor the Sentencing Guidelines control the outcome: failure to conduct a PSI or disputes over criminal history scoring do not render such sentences unlawful. In line with enduring precedent, consecutive life sentences for multiple victims remain lawful when commensurate with culpability.

Beyond resolving Riley’s claims, the Court’s admonition to provide reasoned orders signals an institutional commitment to transparent, reviewable decision-making. The opinion will guide practitioners and courts on when Rule 27.03 applies, how to assess claims of unlawfulness in mandatory life cases, and why jurisdictional dismissals grounded in Chapter 590 timing are improper. As such, Riley serves as a practical and doctrinal compass for postconviction sentencing litigation in Minnesota.