State v. Loeffler

I cannot agree with the majority that appellant was entitled to a formal complaint for this petty misdemeanor speeding charge. But assuming for the sake of argument that he is, not every violation of a procedural rule requires reversal of a conviction. See generally Minn. R.Crim. P. 31.01 (providing that errors not affecting substantial rights should be disregarded). Even violations of rules that protect a defendant’s constitutional rights do not automatically give rise to so severe a sanction. See State v. Jackson, 472 N.W.2d 861, 863 (Minn.1991) (holding violation of prompt arraignment rule…