# Chambers v. State

> Supreme Court of Minnesota · May 31, 2013 · 831 N.W.2d 311

URL: https://www.frixlaw.com/law-library/cases/8246863

## Case

- **Full name:** Timothy Patrick CHAMBERS v. STATE of Minnesota
- **Court:** Supreme Court of Minnesota
- **Decided:** May 31, 2013
- **Citations:** 831 N.W.2d 311; 2013 Minn. LEXIS 313; 2013 WL 2364079
- **Precedential status:** Published
- **Opinion:** Concurrence by Andersonbarry
- **Judges:** Anderson, Barry, Dietzen, Paul, Wright
- **Cited by:** 54 later opinions in the Frix Law Library

## Citator (automated)

- **Red flag:** Overruled by Prentis Cordell Jackson v. State of Minnesota, 2016 Minn. LEXIS 485 (2016).
- Negative treatments: 1
- Distinguished by: 0
- Full citator and citing cases: https://www.frixlaw.com/law-library/cases/8246863

## How later opinions describe it (automated extraction)

- concluding the rule in Miller is procedural and not substantive because first, the rule does not categorically ban life imprisonment without parole for juveniles convicted of homicide; second, relevant federal decisions, i.e. Craig, have concluded Miller is procedural; and thi…
- reasoning that the Miller rule is procedural, inter alia, because it "does not eliminate the power of the State to impose the punishment of life imprisonment without the possibility of release upon a juvenile offender who has committed a homicide offense.”
- concluding that Miller does not establish a watershed rule because it focuses exclusively on sentencing and does not alter bedrock procedural elements essential to fairness of a proceeding
- holding that Miller v. Alabama, 567 U.S. 460, 132 S.Ct. 2455, 183 L.Ed.2d 407 (2012), did not apply retroactively to cases on collateral review

## Opinion text

ANDERSON, G. BARRY, Justice
(concurring).
I join the majority opinion because I agree with the majority’s analysis that under existing precedent the rule in Miller v. Alabama, — U.S. -, 132 S.Ct. 2455 , 183 L.Ed.2d 407 (2012), does not apply retroactively to cases on collateral review. I write separately to observe that any modification of the existing precedent should be left to the United States Supreme Court, whether here or in some other case, because the Court has determined the constitutional limits that underlie Miller , and it is United States Supreme Court jurisprudence at issue in the matter before us. The parties here did not brief other potential avenues for relief under Minnesota law, so contrary to the dissent, I would not reach those questions. I believe such issues are better left for another day, with a better record, and perhaps a clearer explanation of retroactivity doctrine by the United States Supreme Court.

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Source: Frix Law Library, https://www.frixlaw.com/law-library/cases/8246863. Public record. Not legal advice.