Three Unconstitutional Criminal Charges

Three of the Four Felony Charges on Matt Guertin's Docket Were Never Valid Under Minnesota Law. They Are Still There.

On March 23, 2023 — 61 days after his arrest — Guertin emailed his private defense counsel Bruce Rivers a research memo concluding that Minn. Stat. § 609.667(3) does not criminalize the possession of privately made firearms under federal law. On August 6, 2025, the Minnesota Supreme Court issued its published opinion in State v. Vagle, A23-0863, holding exactly that. The opinion was released 20 hours and 32 minutes after Guertin named the court's 426-day withholding of the opinion on the record in 8th Circuit Case 25-2476 on August 5, 2025 at 1:28 PM. The ruling nullified Counts II, III, and IV against Guertin by operation of law. 257 days later, the charges are still on his docket, still classified as felonies, still with Hennepin County Attorney as the prosecuting agency.

3 of 4 Felony Counts Invalidated by Vagle
426 Days the MN Supreme Court Held A23-0863
20h 32min Gap Between Guertin's 8th Cir. Filing and Release
257 Days Since Vagle · Charges Still on Docket

What the Docket Still Says

The current MCRO docket for State of Minnesota v. Matthew D. Guertin, 27-CR-23-1886, pulled on March 29, 2026 at 5:29 PM, lists four felony charges tied to the events of January 21, 2023 in Minnetonka. Three of the four cite a single statute — Minn. Stat. § 609.667(3). That is the statute the Minnesota Supreme Court struck down 257 days ago in State v. Vagle. It has not been dismissed, amended, consolidated, or annotated on the docket since.

Count Charge Statute Level Post-Vagle Status
I Dangerous Weapons — Reckless Discharge of Firearm Within a Municipality 609.66.1a(a)(3) Felony Unaffected
II Firearm-Serial Number — Receive/Possess With No Serial Number 609.667(3) Felony Nullified · A23-0863 · 2025-08-06
III Firearm-Serial Number — Receive/Possess With No Serial Number 609.667(3) Felony Nullified · A23-0863 · 2025-08-06
IV Firearm-Serial Number — Receive/Possess With No Serial Number 609.667(3) Felony Nullified · A23-0863 · 2025-08-06
Source: MCRO docket PDF for 27-CR-23-1886, pulled 2026-03-29 at 5:29 PM. Page 3 reproduces the Charges section verbatim from Hennepin County's own Case Management System.

The docket was pulled 257 days after the Minnesota Supreme Court published Vagle. Counts II, III, and IV have not been amended, dismissed, consolidated, or annotated. They are listed — today — as felonies under the statute the Supreme Court held does not reach the conduct alleged.

The Research Memo the Defense Did Not File

Sixty-one days after his arrest, Matt Guertin emailed his privately retained defense counsel Bruce Rivers a four-source research memo concluding that the three counts under § 609.667(3) were not sustainable under Minnesota or federal law. The timestamp on the email is 2023-03-23 17:34:21 UTC12:34 PM Central. The email authenticates DKIM/SPF‑PASS out of ProtonMail. Rivers forwarded it to his own inbox four minutes later. A four-email thread followed the same afternoon, with a final follow-up on March 24, 2023 at 4:26 PM Central.

What the memo laid out, in 2023, was the reading the Minnesota Supreme Court adopted in 2025: federal law does not require serial numbers on privately made firearms, and Minnesota has not established an independent serial-number regime that reaches them. Nothing was filed with the court. Counts II, III, and IV stayed on the docket.

“Federal law explicitly allows individuals to manufacture personal-use firearms and imposes no requirement to apply serial numbers to such privately built firearms.”

Guertin, Emergency TRO Motion, 8th Cir. 25-2476, Doc. 06 at p. 22 (Aug 5, 2025) — restating the conclusion of the March 23, 2023 research memo two years and four months later.

The Longest En Banc Deliberation in Minnesota History

Oral argument in State v. Vagle, A23-0863, was held en banc at the Minnesota State Capitol on June 5, 2024. The case presented one question: whether Minn. Stat. § 609.667(3) criminalizes possession of a firearm without a serial number when the firearm is not required to have one under federal law. On August 4, 2025 — 425 days later — Guertin pulled every comparable post-en-banc criminal pre-trial case in the Minnesota Supreme Court's record dating back to September 2014 and put the comparison on paper.

The result was not "slow." It was off the distribution entirely.

Days from En Banc Oral Argument to Published Opinion · MN Supreme Court Criminal Pre-Trial Cases
Mean across 30 comparable cases, 2014–2025 152 days
Median 130 days
90th percentile 283 days
Next-longest case A21-0205 · argued 12-08-2021 336 days
A23-0863 · argued 06-05-2024 · this case 426 days
Source: Exhibit MSC-F, filed into 8th Cir. 25-2476, Doc. 20.1 at p. 51. Underlying dataset compiled from mncourts.gov appellate case management records spanning September 4, 2014 through August 4, 2025. A23-0863 is the single red bar on the exhibit's chart; every other case renders in blue.
Source: Emergency Motion for Temporary Restraining Order and Preliminary and/or Permanent Injunctive Relief, filed into 8th Cir. 25-2476 on 2025-08-05 at 1:28 PM Central. Pages 22–24 name the 426-day withholding of A23-0863 on the record and state the outcome Guertin expected the Court to reach.

“This strongly suggests that the decision has already been reached and would likely be favorable to Appellant, effectively nullifying the three unconstitutional firearm charges and leaving only the reckless discharge count, which carries a maximum two-year sentence.”

Guertin, Emergency TRO Motion, 8th Cir. 25-2476, Doc. 06 at p. 23 · filed 2025-08-05 at 1:28 PM Central

The Gap

Guertin named the delay on the record at 1:28 PM Central on Tuesday, August 5, 2025. The Minnesota Supreme Court released its opinion at 10:00 AM Central on Wednesday, August 6, 2025. Between the two events — from the moment the 8th Circuit clerk stamped Doc. 06 to the moment the Minnesota Appellate Courts Case Management System stamped Opinion-Published on A23-0863 — 20 hours and 32 minutes elapsed.

Aug 5, 2025 · 1:28 PM CT
Guertin files Emergency TRO Motion in 8th Cir. 25-2476. Doc. 06, pp. 22–24, names the 426-day withholding of A23-0863 on the record.
20h 32min
Elapsed
Aug 6, 2025 · 10:00 AM CT
Minnesota Supreme Court publishes the Vagle opinion. Minn. Stat. § 609.667(3) held not to reach Counts II, III, and IV. Reversed and remanded. Thissen, J., authoring; Hudson, C.J., and Procaccini, J., dissenting; Gaïtas, J., took no part.
Minnesota Appellate Courts Case Management System · A23-0863 · Opinion Docket Entry
Case Number
A23-0863
Document Description
Opinion — Published
Status
Final
Docket Entry Type
Opinion
Type of Filing
Published
Filing Date
08/06/2025 10:00 AM
Docket Entry Date
08/06/2025 10:00 AM
Case Disposition
Reversed and Remanded
Authoring Judge
Justice Paul C. Thissen
Dissenting
Chief Justice Natalie E. Hudson · Justice Karl C. Procaccini
Took no part
Justice Theodora K. Gaïtas
Source: Exhibit MSC-E2, filed into 8th Cir. 25-2476, Doc. 20.1 at p. 49. Reproduced verbatim from the Minnesota Appellate Courts Case Management System case-maintenance screen on the day of publication.
The opinion did not take 427 days to write. The opinion took 426 days to withhold.

Minn. Stat. § 609.667(3) Does Not Reach Guertin's Conduct

The Minnesota Supreme Court's syllabus in State v. Vagle, A23-0863 (Minn. Aug. 6, 2025), reads in full:

“Minnesota Statutes section 609.667(3) (2024) criminalizes the possession of a firearm without a serial number only when the firearm must have a serial number under federal law.”

“Reversed and remanded.”

Thissen, J., writing for the majority · Gaïtas, J., took no part · Hudson, C.J., and Procaccini, J., dissenting

Applied to Guertin: he built an AR-15, a Glock-19, and a Glock-23 for personal use in the summer of 2020. Federal law does not require privately made firearms to carry serial numbers. Under Vagle, Counts II, III, and IV do not state an offense. The majority's holding does that work automatically — no discretionary reading is required, no additional motion is required, and the statutory analysis admits of no alternative outcome on the facts the State itself charged.

The dissent by Chief Justice Hudson is a 4,766-word, sixteen-page argument whose practical conclusion — as Guertin's own Judicial Notice motion observes — is that Guertin could have complied with the statute by engraving “1,” “2,” and “3” on the three frames. Even the dissent does not argue that the charges were valid as filed. It argues only that a different form of self-selected numbering would have satisfied the statute.

Every Minnesota Outlet That Covered the Decision Reached the Same Conclusion

Within six days of publication, seven Minnesota sources — from Anders Erickson's own law firm (counsel of record for Vagle) to Republican state senators to KARE 11 — reported the same thing: the Minnesota Supreme Court had held that the statute underpinning "ghost gun" charges does not reach privately built personal-use firearms. The conclusion was not novel to lawyers in the state. It was the reading Guertin's research memo had reached 865 days earlier.

2025-08-06
Johnson Erickson Criminal Defense · Counsel of Record
Firm post announcing client's ghost-gun charge dismissed
“The Minnesota Supreme Court agreed with Anders Erickson's argument that Minnesota law does not require that privately made firearms include serial numbers and dismissed client's felony charge.”
2025-08-06
KARE 11 · NBC Minneapolis – St. Paul
Minnesota Supreme Court: ghost guns can be legal
“The Minnesota Supreme Court ruled ghost guns can be legal as federal law doesn't mandate serial numbers for certain firearms.”
2025-08-06
Kroc News · Rochester, MN
Ghost gun charge dropped after Minnesota Supreme Court ruling
“GHOST GUN CHARGE DROPPED AFTER MINNESOTA SUPREME COURT RULING.”
2025-08-06
Minnesota Senate Republican Caucus
Mathews, Mekeland statement on Supreme Court firearms decision
State senators' same-day public statement confirming the holding and its scope under Minnesota law.
2025-08-07
KTTC · NBC Rochester / Mason City / Austin
MN Supreme Court rules ownership of "ghost guns" is legal in state
“MN Supreme Court rules that ownership of 'ghost guns' is legal in state.”
2025-08-08
Alpha News · Minnesota
Legislators call for "witch hunt" against Minnesota gun owner to end following Supreme Court ruling
Legislative response pointing to the Vagle ruling as the basis for terminating prosecutions of Minnesotans charged under the now-narrowed statute.
2025-08-12
Minneapoli Media · Coon Rapids, MN
Minnesota Supreme Court Legalizes "Ghost Guns," Setting Stage for Legislative Showdown
Local coverage framing the ruling as an ongoing statewide policy matter six days after publication.

Motion for Judicial Notice of the Favorable Opinion

On October 4, 2025, Guertin filed a formal Motion for Judicial Notice under Fed. R. Evid. 201(b)(2) in 8th Cir. 25-2476, asking the Court to take notice of three facts: that he had predicted the outcome of the 426-day deliberation within 21 hours; that the Chief Justice's 4,766-word dissent amounted to the proposition that scratching "1," "2," and "3" onto the three frames would have avoided the charges; and that the majority opinion contains a provably false factual claim about a Minnesota DNR firearms auction that compressed six unserialized firearms from a private Hiller auction into the record as evidence of state-sanctioned unserialized sales.

Six exhibits accompany the motion: MSC-A (the opinion itself, 45 pages, SHA-256 hashed); MSC-B and MSC-C (the actual MN DNR auction pages showing every firearm did have a serial number); MSC-D (the Hiller auction page); MSC-E (the Minnesota Appellate Courts Case Management screen captures reproduced in § 04 above); and MSC-F (the statistical outlier graph reproduced in § 03).

Source: Motion for Judicial Notice of Favorable Minnesota Supreme Court Opinion, filed into 8th Cir. 25-2476 on October 5, 2025. Six-page motion body followed by 45 pages of the Vagle opinion, screen captures of the A23-0863 docket, and the statistical outlier graph reproduced on this page.

“This sequence establishes that Appellant's statement was validated as being 100% factually accurate less than 21 hours after being made.”

Motion for Judicial Notice, 8th Cir. 25-2476, Doc. 20.1 at p. 3 · filed October 5, 2025

What Guertin's Own Public Defender Said on Zoom Two Days Later

Two days after Guertin filed the Motion for Judicial Notice, a Rule 20 calendar hearing went forward on Zoom before Referee Lori Skibbie. The attorney-client conference preceding the hearing was recorded. Raissa Carpenter, Guertin's appointed public defender, opened with Vagle.

Video · October 7, 2025 · Attorney-Client Conference · 27-CR-23-1886
Card 002 · 2025-10-07 · State of Minnesota v. Matthew D. Guertin, 27-CR-23-1886 · Hennepin County Fourth Judicial District · Referee Lori Skibbie calendar · 24.68 seconds · Attorney-client conference with Public Defender Raissa Carpenter preceding the hearing.
Ms. Carpenter
“I think it helps us that that Supreme Court decision in the Vagle case came out in your favor. I don't know if you saw my email about that.”
Mr. Guertin
“Yeah, it came out the day after I brought it up. 22 hours later.”
Ms. Carpenter
“So that's in our favor, but I don't know if they'll let us litigate it while you're still not competent to proceed.”
Mr. Guertin
Litigate what? The charges aren't valid anymore.
Ms. Carpenter
“Yeah, I hear you.”

That is Guertin's appointed defense counsel, on the record, acknowledging that the charges are not valid — and saying in the same breath that the competency framework will be used to prevent litigating it. The contradiction is the argument. One person in the exchange has the Minnesota Supreme Court's published syllabus in front of them. The other person on the exchange has the state's procedural machinery in front of them. Both are present in the same meeting, on the same case, about the same three charges, with the same filing date, and the answer is "I hear you."