Legal Memorandum: The void-for-vagueness Doctrine in MN

Issue: Under Minnesota law, may a statute be held unconstitutional using the void-for-vagueness rule?

Area of Law: Litigation & Procedure
Keywords: The void-for-vagueness doctrine; Vague statutes; Void
Jurisdiction: Minnesota
Cited Cases: 431 N.W.2d 868
Cited Statutes: None
Date: 09/01/2014

“The void-for-vagueness doctrine requires that a law be definite, i.e., that ordinary people can understand what conduct is prohibited and the statute does not encourage arbitrary and discriminatory enforcement.”  State v. Newstrom, 371 N.W.2d 525, 528 (Minn. 1985).

“Vague statutes are prohibited under the due process clause of the fourteenth amendment.”  State v. Hyland, 431 N.W.2d 868, 872 (Minn. Ct. App. 1988).  “Vague laws are prohibited because they trap the innocent by not providing adequate warning of unlawful conduct and unleash the potential for unfair and uneven law enforcement by not establishing minimal guidelines.”  Id.  Thus, “a statute is void due to vagueness if it defines the forbidden or required act or acts in terms so vague that individuals must guess at its meaning.”  Humanensky v. Minn. Bd. Md. Exam’rs, 525 N.W.2d 559, 564 (Minn. Ct. App. 1994).


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