Byington v. State
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Appellant's petition for postconviction relief and vacating Appellant's conviction and sentence, holding that, in a postconviction proceeding, a district court has the authority under Minn. Stat. 590.04, subd. 1 to order the State to refund restitution that the defendant has paid because of a conviction when that conviction has been invalidated and no retrial will occur.
Appellant was convicted of one count of violating Minn. Stat. 609.27, subd. 1(4). Later, subdivision 1(4) was declared facially overbroad and unconstitutional. In her petition for postconviction relief, Appellant asserted that, under Nelson v. Colorado, 581 U.S. __ (2017), she was entitled to a refund of all restitution payments made because of her invalid conviction. The district court vacated her conviction and sentence but denied her request for a refund of restitution on the grounds that it lacked authority to do so. The court of appeals affirmed. The Supreme Court reversed, holding that, in a postconviction proceeding, a district court has the authority to order a refund of restitution when the monetary assessments the defendant paid were imposed solely because of the conviction, the State exacted those assessments, and the conviction was invalidated with no prospect of retrial.
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