First-degree criminal sexual conduct charge dismissed
Case
State v. Jackson
62-CR-22-6228
Ramsey County District Court
2nd Judicial District
Minnesota Court of Appeals
A24-0623
December 23, 2024
Charge dismissed, affirmed on appeal, and Supreme Court review denied. Case closed.
The client was charged with first-degree criminal sexual conduct under Minn. Stat. § 609.342 — a felony carrying a maximum sentence of 30 years and a presumptive commitment of 144 months in prison.
The complaint was issued as a warrant in October 2022. The client was not arrested on that warrant until November 2023 — more than twelve months later. During that entire period, he was living at the same address he had provided to law enforcement, which was also listed on the face of the complaint-warrant itself.
The legal approach
Thomas moved to dismiss the charge on Sixth Amendment speedy trial grounds, applying the four-factor Barker v. Wingo balancing test as adopted by the Minnesota Supreme Court in State v. Osorio and Doggett v. United States.
The motion presented the constitutional argument across all four factors: the twelve-month delay was presumptively prejudicial; the government bore full responsibility for it, having known the client’s address throughout; the client asserted his speedy trial right at the very first opportunity available under the Minnesota Rules of Criminal Procedure after being arraigned; and the delay caused presumptive prejudice by destroying potentially exculpatory evidence — including bus station surveillance footage, physical evidence that was never collected at the time of the arrest, and the opportunity to canvass witnesses while memories and evidence were still available.
Thomas also turned the government’s own complaint against it.
The complaint had described the client as an extreme risk to public safety with a lengthy and violent criminal history — and simultaneously, the government had done nothing to arrest him for more than a year, despite knowing precisely where he lived. The motion placed that contradiction directly before the court: if the government truly believed the client posed an extreme danger, its year-long inaction was inexplicable. If the inaction was intentional, it should weigh heavily against the State. If it was negligence, it still weighed against the State — and either way, the client’s constitutional right had been violated.
The result
The District Court agreed and granted the motion to dismiss in April 2024.
The State appealed, arguing that the twelve-month delay was insufficient to establish a speedy trial violation and that the client had not demonstrated actual prejudice. The Minnesota Court of Appeals affirmed the dismissal in December 2024, finding that all four Barker factors weighed against the State or were neutral, and that the one-year delay between charging and arrest was excessive and presumptively prejudiced the client’s ability to mount a defense.
The State petitioned the Minnesota Supreme Court for further review. The Supreme Court denied the petition in March 2025. The dismissal stands.
The case is closed.
Disclaimer
This case has been anonymized to protect client confidentiality. Past results do not guarantee or predict future outcomes. Every case is different, and the result in any particular matter depends on its specific facts, the applicable law, and the circumstances of each client.
