State v. Royster

590 N.W.2d 82 (1999)

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State v. Royster

Minnesota Supreme Court
590 N.W.2d 82 (1999)

  • Written by Rose VanHofwegen, JD

Facts

Stanley Royster (defendant) was charged with trafficking drugs after police found a bag containing nearly three grams of crack cocaine, prerecorded drug-buy money, and a loaded revolver in his bedroom. The gun was under Royster’s mattress, about three feet away from where the cocaine was hidden. Royster admitted he sold cocaine out of his home and said his father gave him the gun for protection because Royster lived in a dangerous neighborhood. The trial court found the gun’s presence triggered a Minnesota statute imposing a mandatory minimum three-year sentence for possession and use of a gun while committing a predicate felony offense. Royster appealed, arguing that the statute as amended incorporated language from an earlier version that required brandishing, displaying, threatening someone with, or otherwise using the gun during commission of the crime—not merely having a gun hidden under the mattress.

Rule of Law

Issue

Holding and Reasoning (Stringer, J.)

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Casebooks

Corrections and Sentencing

Key Terms

  • Constructive PossessionThe power to control an item without physical possession of it. Constructive possession can be used in criminal contexts, as when a person has power over an item and the intent to exercise control over it, or in civil cases, as when a buyer has received title to property but not yet physically occupied it.
  • Compound OffenseA criminal offense that is comprised of two or more independent lesser offenses.
  • Predicate OffenseOne of two or more criminal offenses that must be proved in order to establish all the elements of a compound offense.
  • Sentence EnhancementThe availability of a more severe penalty for certain crimes, based on egregious circumstances that aggravate the seriousness of the crime, such as the use of violence, or the defendant's prior criminal record.

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