State v. Goff

COYNE, Justice.

In State v. Edmison, 379 N.W.2d 85, 86 (Minn.1985), we held that “if a criminal defendant properly raises the issue, * * * then the sentencing court may not use a prior misdemeanor conviction in computing the presumptive sentence under the Sentencing Guidelines for the current offense unless the state proves that the prior conviction was not obtained in violation of the defendant’s right to counsel.” We now hold that in order to raise the issue with respect to a prior conviction — felony, gross misdemeanor, or misdemeanor — a defendant must do more than simply request that the…