State v. Jones

PAGE, Justice

(dissenting).

I respectfully dissent. In this appeal, the record presented is insufficient for purposes of determining whether the district court abused its discretion when it decided that Jones was ineligible for a public defender.

Under Minn.Stat. § 611.17(a)(2) (2008), a defendant who is financially unable to obtain counsel is entitled to the appointment of a public defender. A defendant is financially unable to obtain counsel if he or she, “through any combination of liquid assets and current income, would be unable to pay the reasonable costs charged by private counsel in that judicial district for a defense of the same matter.” Id. The requirements of Rule 5.02, subdivision 3(2), of the Minnesota Rules of Criminal Procedure parallel those of section 611.17(a)(2). To determine financial eligibility, the district court is required to “make appropriate inquiry into the financial circumstances” of the defendant. Minn.Stat. § 611.17(b) (2008). The defendant must “submit a financial statement under oath or affirmation setting forth the applicant’s assets and liabilities.” Id. Further, the “burden is on the [defendant] to show that he or she is financially unable to afford counsel.” Minn. R.Crim. P. 5.02, subd. 4.

Section 611.17 also requires a district court to consider more than just the income of a defendant who applies for a public defender. See also Minn. R.Crim. P. 5.02, subd. 5 cmt. (“[T]he public defender can be appointed for the person of moderate means who would be subject to substantial financial hardship if forced to pay the full cost of adequate representation.”). We have held, as recently as 2002, that a “district court must exercise its discretion to determine whether [a defendant] has met his burden of establishing that through any combination of liquid assets and current income he would be unable to pay the reasonable costs charged by private counsel for defense of a case.” In re Stuart, 646 N.W.2d 520, 527 (Minn.2002); see also Hanson v. Passer, 13 F.3d 275, 279 (8th Cir.1994) (“[t]he phrase ‘financially unable to obtain counsel’ does not require a showing of indigency to entitle an accused to counsel; it is a less stringent standard”). In Stuart, because the district court chose not to consider the liquidity of a defendant’s real estate holdings, we remanded the case, concluding that the dis*508trict court failed to exercise its discretion in determining eligibility. 646 N.W.2d at 526. Although adopting wholesale the use of objective criteria like the poverty guidelines would streamline the eligibility process, it defeats the purpose of the statutory scheme that requires consideration of a defendant’s assets, liabilities, and financial circumstances. Thus, under Stuart, a district court that adopts the use of only the poverty guidelines has not met its duty to conduct a full financial inquiry and has failed to exercise its discretion.

It appears Jones applied for, and was denied, the appointment of counsel four or five times, but only two of the applications are in the record — one dated May 5, 2006, and one dated February 14, 2007.1 Both of these applications were denied. The denials of these two applications are at issue in this case. Because the court below failed to make any findings or explain its reasons for denying the applications on the record in any meaningful way, it is impossible to apply an abuse of discretion standard of review to the court’s denials of these applications.

In his May 5, 2006, application, Jones listed no income, monthly expenses of $2,000, and a car valued at $17,000 but with a balance owed of $17,000. Jones also listed three dependent children, one of whom lived with him and his girlfriend. The application also included information about his girlfriend’s monthly income of $2,080 and monthly expenses totaling between $1,384 and $1,484 for the car, insurance, and child support payments. According to the application, Jones’ rent and food were paid for by Jones’ sister. The application contained no information as to “the reasonable costs charged by private counsel in that judicial district for a defense of the same matter.” At the top of the form, the words “deny - over guidelines” were circled.

The February 14, 2007, application was similarly denied. That application listed the combined monthly income of Jones and his girlfriend as $3,784 and their monthly expenses as $3,592. At some point, the application was amended to show that Jones and his girlfriend had a combined monthly income of approximately $4,500 and monthly expenses of approximately $3,000. The application also showed that Jones owned a car valued at $2,000, and that his girlfriend was pregnant with a due date on March 7. Like the May 5, 2006, application, the February 14, 2007, application contained no information as to the reasonable costs of private counsel, nor is that information found anyplace else in the record. In the transcript of the hearing at which the February 14 application was discussed, the district court asked the court collector to explain why Jones’ public defender application was denied. The court collector testified that Jones’ income, $2,280, was, by itself, over 125% of the federal poverty guidelines. This was the only reason given for the denial.

The court, based on its reading of the record before us, concludes that the district court did not abuse its discretion when it denied Jones’ public defender applications. The record, however, belies the court’s conclusion. First, with respect to the May 5, 2006, application, the only indication as to the reason for the denial comes from the application itself, on which the words “deny - over guidelines” were written. If, as it appears from the application that the only reason for the denial was that Jones’ income was above the poverty *509guidelines, the denial was an abuse of the district court’s discretion because the statutory scheme requires consideration of a defendant’s financial circumstances including liquid assets, current income, assets, liabilities, and the reasonable costs associated with paying for private counsel. On the record before us, there is no indication that the district court considered any of these factors. But even if the district court considered all the information contained on the application, I would still conclude that the court abused its discretion. Assuming without deciding that it was appropriate for the district court to impute to Jones the income of his girlfriend, the difference between Jones’ monthly income and expenses was approximately $500, and the record discloses no assets of substantial value. In denying the application, the district court did not explain why the $500 difference between monthly income and expenses was sufficient to “pay the reasonable costs charged by private counsel in that judicial district.” Nor does this court explain why the $500 difference between monthly income and expenses is sufficient to pay the reasonable costs of representation. To the extent that the court’s opinion holds that a $500 monthly difference between Jones’ income and expenses is sufficient to pay the reasonable costs for private representation, the court should explain why such an amount is sufficient. But the court has not done so. Nor can it do so on this record without engaging in improper fact-finding.

Second, with respect to the February 14, 2007, application, the only reason given by the court collector for the denial was that Jones’ income alone exceeded the poverty guidelines. Again, a denial for that reason alone was an abuse of the district court’s discretion, as it was with the denial of the May 5, 2006, application. I conclude that the district court abused its discretion, even if it considered all the information contained on the February 14 application. Though the difference between Jones’ monthly income, including that of his girlfriend’s, and Jones’ monthly expenses was $1,500, there is still nothing in the record to explain why $1,500 in excess of income over Jones’ expenses is sufficient to “pay the reasonable costs charged by private counsel in that judicial district.” Further, the record reflects that Jones had retained private counsel in a separate matter. None of these costs were included in the application, let alone in the district court’s eligibility determination.2

For the reasons discussed above, I conclude that the district court abused its discretion when it denied Jones’ May 5, 2006, and February 14, 2007, applications for a public defender. To the extent that the court is correct in its conclusion that the district court conducted an appropriate inquiry into Jones’ financial circumstances, I would remand to the district court for further explanation because, on the record before us, it is impossible to determine whether the denials were an abuse of discretion.

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. Copies of the applications are attached as addendum 1 and 2 respectively. For reasons of privacy, certain information contained on the applications, but not relevant to our discussion, has been redacted.

. The application for a public defender is a one-page form, and there are only two blanks for an applicant to list liabilities. Although Jones mentioned his other legal matter to the district court, the particulars of that arrangement did not appear on the application, even after he was interviewed by the court collector.