State v. Spain
Minnesota Supreme Court
590 N.W.2d 85 (1999)
Nancy Spain (defendant) set fire to her ex-husband Eugene Letendre's bedroom while he slept, causing him serious burns and lasting pain; expert testimony refuted her claim the fire was accidental. She was convicted of first-degree arson. Despite having no prior criminal record, the trial court sentenced her to 144 months — three times the 48-month presumptive sentence — citing factors like premeditation, cruelty, and Letendre's suffering. The court of appeals affirmed, and the state supreme court reviewed the sentence.
Whether a trial court must adhere to the general sentencing guidelines unless aggravating circumstances warrant a double departure, or severe aggravating circumstances warrant a greater departure, from the presumptive sentence.