The Minnesota Supreme Court issued a decision Tuesday clarifying jurisdictional rules for sentence correction motions, reversing a district court's dismissal of a pro se prisoner's challenge to his mandatory life sentences.

In *Adrian Dominic Riley v. State of Minnesota*, the high court held that the Carver County District Court erred in concluding it lacked jurisdiction to hear Riley's motion to correct his sentences under Minnesota Rule of Criminal Procedure 27.03, subdivision 9. Riley, also known as Amiri Abdul Rasheed-El, filed the motion challenging only the lawfulness of his mandatory life sentences for first-degree murder.

The Supreme Court's decision centers on the proper application of procedural rules governing sentence challenges and statutory limitations periods. Writing for the court, Justice Moore III addressed two key legal issues that have implications for future sentence correction motions in Minnesota courts.

First, the court applied its precedent from *Reynolds v. State* (2016) to determine that Riley's motion was not subject to the limitations period imposed by Minnesota Statutes section 590.01, subdivision 4. The *Reynolds* decision established important parameters for when statutory time limits apply to different types of post-conviction challenges.

Second, even if the limitations period did apply, the court relied on *Carlton v. State* (2012) to clarify that the limitations period imposed by section 590.01, subdivision 4 is not jurisdictional in nature. This distinction is crucial because jurisdictional defects cannot be waived and must be raised by courts even when parties do not assert them.

Riley's case arose from his conviction for first-degree murder, which carried statutorily mandated life sentences. He challenged these sentences by filing a pro se motion alleging procedural errors, including the absence of a presentence investigation and alleged miscalculation and improper weighing of his criminal history score.

The district court dismissed Riley's motion, concluding it lacked jurisdiction to consider the challenge. This dismissal prompted Riley's appeal to the state's highest court, where he continued to represent himself without counsel.

The case was handled by Attorney General Keith Ellison's office for the state, along with Carver County Attorney Mark A. Metz and Chief Deputy County Attorney Peter A. C. Ivy representing the prosecution's interests.

While the Supreme Court found the district court erred on jurisdictional grounds, the decision indicates the lower court ultimately reached the correct outcome in dismissing Riley's challenge. The court noted that because Riley was sentenced to statutorily mandated life sentences for first-degree murder, the procedural issues he raised did not render his sentences unlawful within the meaning of Minnesota rules.

This aspect of the ruling highlights an important limitation on sentence correction motions: even when procedural errors occur, they may not provide grounds for relief if the underlying sentence was statutorily required and therefore legally correct.

The decision provides clarity for Minnesota courts handling similar motions going forward. District courts must properly analyze their jurisdiction using the framework established in *Reynolds* and *Carlton*, rather than incorrectly concluding they lack authority to hear legitimate sentence challenges.

The ruling also demonstrates the complexity of post-conviction proceedings, particularly for pro se litigants who must navigate procedural requirements without legal counsel. Riley's case shows how jurisdictional questions can become entangled with substantive challenges to criminal sentences.

For practitioners, the decision reinforces that courts should carefully distinguish between jurisdictional and non-jurisdictional procedural requirements when considering sentence correction motions. The *Carlton* precedent's clarification that section 590.01's limitations period is not jurisdictional prevents courts from dismissing potentially valid challenges on improper grounds.

The case filed as A24-1702 was decided October 22, 2025, and reflects the Supreme Court's ongoing effort to clarify procedural rules governing post-conviction challenges in Minnesota's criminal justice system.

While Riley's specific challenge was ultimately unsuccessful due to the mandatory nature of his life sentences, the procedural clarifications provided by the Supreme Court ensure that future sentence correction motions receive proper jurisdictional analysis. This protects the rights of defendants to challenge potentially unlawful sentences while maintaining appropriate procedural safeguards.