Reseña de State v. Frazier

State v. Frazier de State of Minnesota in Supreme Court Resumen del Libro

OPINION William Allen Frazier pleaded guilty to one count of a controlled substance crime committed for the benefit of a gang. Despite his plea, Frazier asked the district court to sentence him without regard to the crime committed for the benefit of a gang statute, Minn. Stat. § 609.229 (2000). He argued that the statute, as applied, denies equal protection and due process under the federal and state constitutions. In support of his argument, Frazier presented data which he asserted indicated that section 609.229 has a disparate impact on the basis of race. The district court found that Frazier's data demonstrated that section 609.229 has a disparate impact on racial minorities. Nevertheless, the court ultimately rejected Frazier's constitutional argument, finding that the statute survived constitutional scrutiny under Minnesota's active rational basis test. On appeal, the Minnesota Court of Appeals did not address whether Frazier's data demonstrated disparate impact, apparently accepting the district court's finding. However, the court of appeals concluded that the statute survived our active rational basis test. We affirm, but on different grounds.

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