In Heilman v. Courtney, the Minnesota Supreme Court decided that a person convicted of a felony-level Driving While Intoxicated offense (felony DWI) is “released from prison” under Minnesota statute when he departs from prison to participate in Phase II of the Challenge Incarceration Program. The court made this determination based on the language in the felony-DWI conditional release statute and the statutes governing the Challenge Incarceration Program. Justice Lillehaug issued a strong dissent to the majority’s decision, noting that the majority strayed from the legislative intent behind the aforementioned statutes and other relevant statutes.
This case note begins with the relevant statutory history and case law underlying the Heilman decision. Next, it describes the facts, relevant procedural history, and the court’s ultimate ruling in Heilman. The analysis demonstrates the court’s error in failing to engage in a complete statutory interpretation. The case note then engages in a complete statutory analysis to explain what should have occurred in Heilman. Additionally, the analysis argues that the court’s determination in Heilman possibly leads to an equal protection violation.