State v. Schnell, No. A17-1895 (Minn. 2019)
Nature of Case: Appellant filed a writ of habeas corpus alleging that his incarceration was unlawfully extended into his conditional release term as a result of the failure of the Minnesota Department of Corrections to approve housing. The trial court found that the DOC had failed to adhere to the requirements of the law, and either approve housing for Appellant or modify his conditions of conditional release.
The DOC release Appellant from incarceration into a residential treatment program, and the DOC moved to dismiss Appellant’s writ as moot. The trial court found that it was not moot, given Appellant’s risk of re-incarceration for lack of approved, suitable housing. The DOC appealed, and the Court of Appeals reversed, finding that the writ was mooted when he was released to the treatment program. Appellant sought further review.
Holding: Minnesota Supreme Court reversed the Minnesota Court of Appeals. Appellant’s writ was not mooted by DOC’s release of Appellant to the residential treatment facility. Furthermore, DOC failed to properly comply with the law and is required to consider releasing Appellant into a county of his choosing, or else modify his conditions of release.