State of Minnesota v. Kristyn Nicole Schouweiler

OPINION

CHUTICH, Justice.

Appellant Kristyn Nicole Schouweiler was charged with felony issuance of a dishonored check, Minn.Stat. § 609.535, subd. 2 (2014), when her check for past-due property taxes was returned for insufficient funds. The district court dismissed the criminal complaint, concluding that Schouweiler’s check met the statutory exception for “a check given for a past consideration,” id., subd. 5 (2014). The court of appeals reversed, and Schouweiler petitioned for review. We conclude that “a check given for a past consideration” means a check given for a good or service that was…