Adrian Dominic Riley v. State of Minnesota

Minnesota Supreme Court

Adrian Dominic Riley v. State of Minnesota

Opinion

                                   STATE OF MINNESOTA

                                    IN SUPREME COURT

                                        A24-1702

Carver County                                                                  Moore, III, J.

Adrian Dominic Riley,

                      Appellant,

vs.


State of Minnesota,                                                Filed: October 22, 2025
                                                                 Office of Appellate Courts
                      Respondent.
                              ________________________

Adrian Dominic Riley a/k/a Amiri Abdul Rasheed-El, Moose Lake, Minnesota, pro se.

Keith Ellison, Attorney General, Saint Paul, Minnesota; and

Mark A. Metz, Carver County Attorney, Peter A. C. Ivy, Chief Deputy County Attorney,
Chaska, Minnesota, for respondent.
                             ________________________

SYLLABUS

      1.     The district court erred in concluding it lacked jurisdiction to hear appellant’s

motion to correct a sentence under Minnesota Rule of Criminal Procedure 27.03,

subdivision 9, which only challenged the lawfulness of his mandatory life sentences,

because under Reynolds v. State, 
888 N.W.2d 125
 (Minn. 2016), such a motion is not

subject to the limitations period imposed by Minnesota Statutes § 590.01, subdivision 4,

and even if it were, under Carlton v. State, 
816 N.W.2d 590
 (Minn. 2012), the limitations

period imposed by Minnesota Statutes § 590.01, subdivision 4 is not jurisdictional.


                                             1
       2.     Although the district court erred when it concluded that it lacked jurisdiction,

it reached the correct outcome in this case because appellant was sentenced to statutorily

mandated life sentences for first-degree murder, and therefore the absence of a presentence

investigation, as well as the alleged miscalculation and improper weighing of his criminal

history score, did not render his sentences unlawful within the meaning of Minnesota Rule

of Criminal Procedure 27.03, subdivision 9 because the presentence investigation statute

and the Minnesota Sentencing Guidelines do not govern mandatory life imprisonment

sentences for first-degree murder.

       Affirmed.

OPINION

MOORE, III, Justice.

       Appellant Adrian Dominic Riley was convicted of three counts of first-degree

murder and three counts of second-degree murder in 1995 and was sentenced to three

consecutive life sentences. After we affirmed Riley’s convictions on direct appeal in 1997,

he filed several postconviction petitions under Minnesota Statutes § 590.01 (2024), which

were denied. In July 2024, Riley filed his fifth request for postconviction relief—a motion

to correct or reduce his sentence under Minnesota Rule of Criminal Procedure 27.03,

subdivision 9. In his motion, Riley argued that his sentence is unlawful because he did not

receive a presentence investigation (PSI), which would have revealed that he has dyslexia

and a history of childhood physical abuse, and because the district court miscalculated and




                                              2
improperly weighed his criminal history score. 1 Riley argues that the information about

his dyslexia and past abuse, had it been reported to the district court before sentencing, may

have resulted in his receiving concurrent sentences rather than consecutive sentences.

       The State asserted that Riley’s motion was really a petition for postconviction relief

under 
Minn. Stat. § 590.01
. Based on that assertion, the State argued Riley’s claims were

time-barred under 
Minn. Stat. § 590.01
, subd. 4, and then erroneously cited State v. Knaffla,

243 N.W.2d 737
 (Minn. 1976), for the proposition that the statutory time bar is

jurisdictional. The district court agreed with the State and denied Riley’s motion for relief.

The one-page order failed to explain the district court’s reasoning.

       We conclude that the district court erred in treating Riley’s petition as a petition for

postconviction relief under 
Minn. Stat. § 590.01
 rather than as a motion to correct a

sentence under Minn. R. Crim. P. 27.03. But after properly construing Riley’s petition

under Minn. R. Crim. P. 27.03, we nonetheless affirm the district court’s dismissal order

because, despite Riley’s assertion to the contrary, his sentences were not unlawful.

                                          FACTS

       On April 25, 1996, a Carver County jury found Adrian Dominic Riley guilty of three

counts of first-degree murder and three counts of second-degree murder for the shooting



1
       Riley also claimed that his sentence is unlawful because the district court did not
award 351 days of jail credit for time served in the county jail before sentencing. But that
claim is moot because the district court has now granted his jail credit request and the State
does not challenge the award of jail credit.



                                              3
deaths of three people in Watertown Township on May 23, 1995. 2 On April 29, 1996, a

state probation agent submitted a letter to the district court explaining that a presentence

investigation (PSI) would not affect Riley’s sentence because 
Minn. Stat. § 609.185
 (1994)

mandated a life sentence for a first-degree murder conviction. 3 The probation agent noted

that a post-sentence investigation would be completed at the department of corrections

under 
Minn. Stat. § 609.115
 (1994). 
Id.
 On May 10, 1996, the district court sentenced

Riley to three consecutive life sentences.

         Riley has challenged his convictions multiple times. We have affirmed Riley’s

convictions on direct appeal and on review from the denial of multiple postconviction

petitions. 4 State v. Riley, 
568 N.W.2d 518
 (Minn. 1997); Riley v. State, 
792 N.W.2d 831, 832
 (Minn. 2011); Riley v. State, 
819 N.W.2d 162
 (Minn. 2012). But none of Riley’s prior

appeals have challenged his sentences.

         On July 25, 2024, Riley filed the present motion to correct and reduce his sentences

under Minn. R. Crim. P. 27.03, subd. 9. Relevant to this appeal, Riley argued that his


2
         The events of the murders are described in State v. Riley, 
568 N.W.2d 518
 (Minn.
1997).
3
        The relevant statutory language has not changed since Riley’s conviction. See
Minn. Stat. § 609.185
(a) (2024) (“Whoever does any of the following is guilty of murder
in the first degree and shall be sentenced to imprisonment for life . . . .”).
4
       These prior cases are described in Riley v. State, 
819 N.W.2d 162, 165-66
 (Minn.
2012). On June 8, 2017, Riley filed a fourth petition for postconviction relief. The district
court denied Riley’s petition on August 2, 2017. Riley did not appeal the district court’s
order.


                                              4
sentences are unlawful because the district court did not conduct a presentence

investigation before his sentencing. Riley claimed that a presentence investigation would

have revealed that he was diagnosed with dyslexia and that he had a history of childhood

physical abuse. Riley further claimed that this resulted in the sentencing judge applying

the wrong criminal history score, which in turn resulted in his consecutive rather than

concurrent life sentences.    Riley also raised 
Minn. Stat. § 609.133
, which allows

prosecutors to seek sentence adjustments, as an avenue for relief from his consecutive

sentences.

       In its response, the State argued that the district court lacked subject matter

jurisdiction to hear Riley’s petition.   The State cited 
Minn. Stat. § 590.01
, subd. 2

(providing that the postconviction remedy takes the place of any other common law,

statutory or other remedies), for the proposition that a chapter 590 postconviction petition

is the sole remedy to challenge a sentence. Contra Minn. R. Crim. P. 27.03, subd. 9

(allowing a court to correct an unlawful sentence at any time). Having construed Riley’s

motion to correct his sentence as a postconviction petition, the State argued that Riley’s

claims were time-barred under 
Minn. Stat. § 590.01
, subd. 4, 5 and then cited State v.

Knaffla, 
243 N.W.2d 737
 (Minn. 1976), for the proposition that the statutory time bar is

jurisdictional.


5
       A petition for postconviction relief may not be filed more than two years after “the
entry of judgment of conviction or sentence if no direct appeal is filed” or “an appellate
court’s disposition of petitioner’s direct appeal,” unless a statutory exception applies.
Minn. Stat. § 590.01
, subd. 4.

                                             5
       On October 7, 2024, the district court held a hearing on Riley’s motion at which

Riley appeared via Zoom. Later that day, the court issued a one-page order in response to

Riley’s motion. The order stated in full:

       1. The Carver County District Court lacks jurisdiction to hear Defendant’s
          claims.
       2. Defendant’s motion for relief is DENIED in full.
       3. Defendant’s sentence shall be amended to include credit for 351 days
          served prior to adjudication.
       4. All orders unaffected by this order remain in full force and effect.

The district court failed to explain why it lacked jurisdiction or provide any reasoning

behind its order. Riley then appealed to this court.

                                       ANALYSIS

       We first discuss the district court’s decision to treat Riley’s motion to correct a

sentence under Minnesota Rule of Criminal Procedure 27.03, subdivision 9, as a petition

for postconviction relief under Minnesota Statutes § 590.01. We then turn to the merits of

Riley’s motion.

                                             I.

       The distinction between a motion to correct a sentence and a petition for

postconviction relief is based upon the relief sought. Minnesota Rule of Criminal

Procedure 27.03, subdivision 9, provides that “[t]he court may at any time correct a

sentence not authorized by law.” By contrast, 
Minn. Stat. § 590.01
 provides a limited

window of time in which a petitioner can seek broader forms of postconviction relief.

Minn. Stat. § 590.01
, subd. 1 (allowing persons convicted of a crime to file a petition “to



                                             6
vacate and set aside the judgment and to discharge the petitioner or to resentence the

petitioner or grant a new trial or correct the sentence or make other disposition as may be

appropriate”); 
id.,
 subd. 4 (providing a two-year time limit to file a petition for

postconviction relief, subject to certain exceptions).

       In prior cases, we have declined to adopt a definitive standard of review that applies

to a district court’s decision to construe a request for relief styled as a motion to correct a

sentence under Minn. R. Crim. P. 27.03, subd. 9, as a petition for postconviction relief.

See Wayne v. State, 
870 N.W.2d 389
, 391 n.2 (Minn. 2015); Johnson v. State, 
877 N.W.2d 776
, 779 n.3 (Minn. 2016); Bolstad v. State, 
966 N.W.2d 239
, 243 (Minn. 2021). We have

not needed to determine the standard of review because we concluded that the outcome in

those cases would be the same under either de novo or abuse of discretion review. See 
id.

Because here too, we conclude that the outcome would be the same under either standard

of review, we again decline to reach the issue.

       Identifying the nature of Riley’s request for postconviction relief is significant

because a motion to correct a sentence can be brought at any time, while a petition for

postconviction relief is subject to a two-year statute of limitations in the absence of a

statutory exception. See State v. Maurstad, 
733 N.W.2d 141, 147
 (Minn. 2007) (explaining

that under Minn. R. Crim. P. 27.03, subd. 9, illegal sentences are correctable at any time);

compare Minn. R. Crim. P. 27.03, subd. 9, with 
Minn. Stat. § 590.01
, subd. 4.

       In considering whether a motion under Rule 27.03, subd. 9, should be treated as a

petition for postconviction relief, the way that a petitioner characterizes their motion is not


                                              7
dispositive. Instead, we “look to the pleadings and the relief sought in order to determine

the nature of a claim.” State v. Coles, 
862 N.W.2d 477, 480
 (Minn. 2015). When the relief

sought implicates more than a petitioner’s sentence, we have held that a motion should be

construed as a petition for postconviction relief rather than a motion to correct a sentence.

Id.
 at 481–82 (concluding that the appellant’s request for relief fell outside the scope of

Rule 27.03 because the challenge to his sentence would implicate the plea agreement that

gave rise to the sentence).

       In its memorandum to the district court, the State did not argue that the relief Riley

seeks fell outside the scope of Rule 27.03. Instead, the State argued that the postconviction

relief statute, 
Minn. Stat. § 590.01
, provides the exclusive remedy available to Riley. The

State cited 
Minn. Stat. § 590.01
, subd. 2, which states that:

       This remedy takes the place of any other common law, statutory or other
       remedies which may have been available for challenging the validity of a
       conviction, sentence, or other disposition and must be used exclusively in
       place of them unless it is inadequate or ineffective to test the legality of the
       conviction, sentence or other disposition.

To the extent that the State and the district court read this language to require that any

motion to correct a sentence must meet the two-year statute of limitations imposed by

Minn. Stat. § 590.01
, subd. 4, that is incorrect. We explicitly rejected that interpretation in

Reynolds, holding that “[t]o the extent that the limitations period in 
Minn. Stat. § 590.01
,

subd. 4, interferes with the process laid out in [Minn. R. Crim. P. 27.03, subd. 9], the statute

violates the separation of powers.” Reynolds v. State, 
888 N.W.2d 125, 133
 (Minn. 2016).




                                               8
       Here, Riley’s request for postconviction relief challenged his sentence only. It did

not challenge his conviction, and his arguments about his sentence did not implicate any

issues beyond the scope of Rule 27.03, subd. 9. We therefore conclude that Riley’s request

for relief fell within the scope of a motion to correct a sentence under Minn. R. Crim. P.

27.03, subd. 9, and thus the district court erred when it construed the request as a

postconviction petition under 
Minn. Stat. § 590.01
.

       In denying Riley’s motion, the district court simply stated that it lacked jurisdiction

without any further explanation. We are troubled by the district court’s failure to explain

how it reached its conclusions because providing such an explanation is important not only

to reviewing courts, but to the interested parties. To the extent that the district court’s

statement that it “lacked jurisdiction” to hear Riley’s request for relief was based on a

determination that Riley’s claims were time-barred under 
Minn. Stat. § 590.01
, subd. 4,

that statement conflicts with our case law, including Reynolds, 
888 N.W.2d at 133
, and

Carlton, 
816 N.W.2d at 603
. 6 Riley’s claims were therefore properly brought under Minn.

R. Crim. P. 27.03, subd. 9, which allows courts to correct unlawful sentences “at any time,”

and the district court had jurisdiction to hear them.




6
       That the district court concluded that it lacked jurisdiction suggests that the district
court agreed with the State’s argument that Riley’s claims were time-barred, and that the
time bar statute is jurisdictional. But even if Riley’s arguments were time-barred under
Minn. Stat. § 590.01
, subd. 4, the district court would not lack jurisdiction to hear the claim.
See Carlton, 
816 N.W.2d at 603
 (explaining that the time bar is not jurisdictional).


                                               9
                                              II.

       Properly construing Riley’s claims as brought under Minn. R. Crim. P. 27.03, subd.

9, we now turn to the merits of Riley’s motion. The district court failed to reach the merits,

and such a failure would ordinarily require remand to the district court, so that the district

court can provide its reasoning. See, e.g., Waiters v. State, 
14 N.W.3d 279
, 282-83 (Minn.

2024) (describing when remand is necessary). But we will sometimes address issues on

appeal rather than remanding when judicial economy would be served. See Bode v. Minn.

Dep’t of Nat. Res., 
612 N.W.2d 862, 869
 (Minn. 2000) (“It would be an exercise in judicial

inefficiency for us to remand this case to the district court . . . .”); State v. Faber, 
343 N.W.2d 659, 660
 (Minn. 1984) (“[I]n the interest of judicial economy, we will put

substance over form in this case, and . . . will allow the appeal rather than remand . . . .”).

Because Riley’s claims are readily determinable on the record, we conclude that judicial

economy would be best served by addressing the merits on the current appeal, rather than

remanding to district court. 7


7
       In Waiters v. State, we reversed the district court’s summary denial of
postconviction relief and remanded for further proceedings because the record did not
disclose the basis for the district court’s decision. 
14 N.W.3d 279
, 282-83 (Minn. 2024);
see Scruggs v. State, 
484 N.W.2d 24
 (Minn. 1992) (“In an instance where the reviewing
court cannot ascertain whether the postconviction court actually considered one of the
petitioner's claims, remand is appropriate.”). In Waiters, we also acknowledged that where
“the record is clear and yields an obvious answer to the relevant questions raised on
appeal,” remand is not necessary. 
Id.
 at 283 (quoting Scruggs, 
484 N.W.2d at 25
). The
same is true here. 
Id.
 The sole issue before us, whether Riley’s sentence is “contrary to
law or applicable statutes,” is readily determinable based on the record. State v. Schnagl,
859 N.W.2d 297, 301
 (Minn. 2015); see also Bolstad v. State, 
966 N.W.2d 239
, 243 (Minn.
2021) (noting that our standard of review in this context is “arguably de

                                              10
         Under Minnesota Rule of Criminal Procedure 27.03, “[t]he court may at any time

correct a sentence not authorized by law.” Minn. R. Crim. P. 27.03, subd. 9. For a sentence

to be unauthorized, it must be “contrary to law or applicable statutes.” State v. Schnagl,

859 N.W.2d 297, 301
 (Minn. 2015). The sentence must also have been illegal “at the time

it was imposed.” State v. Meger, 
901 N.W.2d 418, 425
 (Minn. 2017) (quoting Reynolds,

888 N.W.2d at 133
). “The defendant bears the burden of proving the facts necessary to

show that a sentence was unauthorized.” Hannon v. State, 
957 N.W.2d 425
, 432 (Minn.

2021).

         On appeal, Riley articulates three reasons that his three consecutive life sentences

are not authorized by law. First, Riley argues that the State failed to conduct a PSI, and

second, Riley argues that the district court miscalculated and improperly weighed his

criminal history score. Riley suggests that both issues resulted in his receiving consecutive

mandatory life sentences rather than concurrent mandatory life sentences. Finally, Riley

suggests that he should receive relief under the prosecutor-initiated sentence adjustment

law, 
Minn. Stat. § 609.133
. We discuss each issue in turn.

         Riley argues that the sentencing court’s decision not to conduct a PSI violated 
Minn. Stat. § 609.115
 and, thus, his sentence was not authorized by law. To succeed on this



novo”). Additionally, resolution of Riley’s claim does not implicate the notice and
forfeiture issues that we noted in Waiters. Cf. Waiters, 14 N.W.3d at 284 n.5. That said,
we reiterate the need for district courts in future cases to explain their reasoning when they
deny postconviction relief or a motion to correct a sentence. Doing so is important not
only to reviewing courts, but to the interested parties.


                                              11
claim, Riley bears the burden of establishing that it was illegal to impose his sentence

without a PSI in 1996. See Hannon, 957 N.W.2d at 432 (“The defendant bears the burden

of proving the facts necessary to show that a sentence was unauthorized.”).

       As the probation agent’s letter points out, a PSI would not have affected Riley’s

sentence because his first-degree murder convictions required mandatory life sentences

under 
Minn. Stat. § 609.185
. But even if a PSI could have influenced Riley’s sentence, his

sentence is not unlawful because the law does not require courts to conduct a PSI. In State

v. Walker, we commented on the PSI requirement in 
Minn. Stat. § 609.115
, explaining that

“no defendant has an absolute right to demand [a PSI].” 
235 N.W.2d 810, 815
 (Minn.

1975). As a result, Riley has no right to have his sentence corrected under Minn. R. Crim.

P. 27.03, subd. 9.

       Riley also claims that the district court based its decision to impose consecutive

rather than concurrent sentences on incorrect information. Riley states that the district

court weighed his criminal history score incorrectly, which led the court to sentence him

to consecutive rather than concurrent life sentences. It is unclear what Riley means by this,

as the record does not show that the district court used a criminal history score at all. 8 Riley

also argues that “my case worker told me that the state used a P.S.I. from 1990.” It is

unclear if these two arguments are related. But regardless, mandatory life sentences were



8
        A criminal history score is a numerical value assigned to an offender under the
Minnesota Sentencing Guidelines based on the sum of points from eligible prior felonies,
custody status at the time of the offense, prior misdemeanors and gross misdemeanors, and
prior juvenile adjudications. See Minn. Sent. Guidelines 2.B (2025).

                                               12
not subject to the sentencing guidelines at the time of Riley’s sentencing in 1996. See

Minn. Sent. Guidelines II, subd. E (1995) (“First degree murder . . . ha[s] a mandatory life

sentence [and is] excluded from the offenses covered by the sentencing guidelines.”). This

remains the case today. See Minn. Sent. Guidelines 2.E(4) (2024) (“Mandatory life

imprisonment sentences for first-degree murder . . . are not governed by the Guidelines.”).

Thus, a person with a criminal history score of zero and a person with a criminal history

score of six would both receive mandatory life sentences for first-degree premeditated

murder, whether in 1996 or today. See Minn. Sent. Guidelines IV (1995); Sanders v. State,

23 N.W.3d. 86, 94 (Minn. 2025) (explaining that a criminal history score is irrelevant when

a defendant receives a mandatory life sentence or sentences).

       Although the record does not contain a PSI, it does contain a sentencing

memorandum from the State arguing for the imposition of consecutive sentences. The

State makes no mention of Riley’s criminal history. Rather, it relies on our case law

affirming consecutive sentences for multiple murders. We have held that “when crimes

are committed against different persons in the same incident, the district court has

discretion to impose one sentence per victim so long as such sentencing does not

exaggerate the criminality of the defendant’s conduct.” State v. Cole, 
542 N.W.2d 43, 53

(Minn. 1996); see also State v. Brom, 
463 N.W.2d 758, 765
 (Minn. 1990) (holding that the

decision to impose three consecutive life sentences for first degree murder was within the

discretion of the district court under 
Minn. Stat. § 609.15
 and subject to appellate review

only to ensure consecutive sentences were “commensurate with culpability and not an


                                            13
exaggeration of defendant’s criminality” (quoting State v. Bangert, 
282 N.W.2d 540, 547

(Minn. 1979))); State v. Warren, 
592 N.W.2d 440, 452
 (Minn. 1999) (reversing the

imposition of concurrent life sentences on the grounds that it understated the criminality

of a defendant who fatally shot three persons).

       Because Riley was convicted of murdering three people, he has not met his burden

to establish that his three consecutive life sentences are contrary to the law. See Sanders,

23 N.W.3d at 93 (“We have repeatedly affirmed the imposition of multiple consecutive

sentences in cases involving violent crimes against multiple victims.”); Hannon, 957

N.W.2d at 432 (Minn. 2021) (“The defendant bears the burden of proving the facts

necessary to show that a sentence was unauthorized.”). Riley thus has no right to have his

sentence corrected under Minn. R. Crim. P. 27.03, subd. 9.

       Finally, we address Riley’s argument that under 
Minn. Stat. § 609.133
, the court

can, if it so chooses, order his sentences to run concurrently.         Minnesota Statutes

section 609.133 does not apply to this case. That statute allows prosecutors, not courts, to

“commence a proceeding to adjust the sentence” of an individual. 
Minn. Stat. § 609.133
,

subd. 2 (2024). Here, the State has not initiated a proceeding to adjust Riley’s sentence, so

Minn. Stat. § 609.133
 provides no relief.




                                             14
       Accordingly, we hold that although the district court erred when it concluded it

lacked jurisdiction, it reached the correct outcome when it concluded that Riley’s motion

to correct his sentences should be denied in full because Riley’s sentences were not

unlawful. 9

                                     CONCLUSION

       For the forgoing reasons, we affirm the decision of the district court on other

grounds.

       Affirmed.




9
       After our nonoral conference and shortly before we issued this opinion, Riley filed
a document captioned “Affidavit of Fact and Notice and Motion for an Ex Parte Hearing,”
citing Minn. R. Civ. P. 41.02 (providing, in part, that the court may “dismiss an action or
claim for failure to prosecute or to comply with these rules or any order of the court”). The
Minnesota Rules of Civil Procedure “govern the procedure in the district courts of the State
of Minnesota in all suits of a civil nature.” Minn. R. Civ. P. 1 (emphasis added). Because
this case involves a proceeding in the supreme court that involves a criminal case, Riley’s
reliance on Minnesota Rule of Civil Procedure 41.02 is misplaced. Accordingly, we deny
his motion.


                                             15


Reference

Status
Published
Syllabus
1. The district court erred in concluding it lacked jurisdiction to hear appellant's motion to correct a sentence under Minnesota Rule of Criminal Procedure 27.03, subdivision 9, which only challenged the lawfulness of his mandatory life sentences, because under Reynolds v. State, 888 N.W.2d 125 (Minn. 2016), such a motion is not subject to the limitations period imposed by Minnesota Statutes § 590.01, subdivision 4, and even if it were, under Carlton v. State, 816 N.W.2d 590 (Minn. 2012), the limitations period imposed by Minnesota Statutes § 590.01, subdivision 4 is not jurisdictional. 2. Although the district court erred when it concluded that it lacked jurisdiction, it reached the correct outcome in this case because appellant was sentenced to statutorily mandated life sentences for first-degree murder, and therefore the absence of a presentence investigation, as well as the alleged miscalculation and improper weighing of his criminal history score, did not render his sentences unlawful within the meaning of Minnesota Rule of Criminal Procedure 27.03, subdivision 9 because the presentence investigation statute and the Minnesota Sentencing Guidelines do not govern mandatory life imprisonment sentences for first-degree murder. Affirmed.