Barnslater v. State, 2011 Minn. App. LEXIS 138

Barnslater entered his former girlfriend J.B.'s home without consent and confronted her male friend in Oct. 2008.
He pled guilty to first-degree burglary under a plea agreement; the district court stayed a 33-month prison sentence and placed him on 10 years' probation.
Probation terms included restitution to J.B.; Barnslater violated probation and the court revoked probation, ordering prison and $500 restitution.
Barnslater appealed the probation-revocation order but later dismissed after restitution was rescinded.
He filed a postconviction-relief petition challenging the validity of his guilty plea, which the district court barred under Knaffla on the theory of a prior appeal.
The court ultimately concluded the Knaffla bar did not apply because the prior appeal was not a direct appeal from conviction, but upheld the plea as supported by a sufficient factual basis.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Knaffla bars the postconviction petition	Barnslater argues prior appeal was not a direct appeal from conviction.	State contends the prior appeal triggered Knaffla bar as a direct appeal.	Knaffla does not bar the petition.
Whether the guilty plea had a sufficient factual basis	Guilty plea lacks sufficient factual basis to prove burglary.	State asserts the plea facts establish burglary via property damage and order-for-protection violation.	Yes; sufficient facts support the plea.

State v. Knaffla, 309 Minn. 246 (Minn. 1976) (direct appeal bars petition for postconviction relief of issues raised)
State v. Iverson, 664 N.W.2d 346 (Minn. 2003) (requires factual basis for guilty plea on record)
State v. Ecker, 524 N.W.2d 712 (Minn. 1994) (guilty-plea factual basis assessed from record and questioning)
State v. Trott, 338 N.W.2d 248 (Minn. 1983) (broadly permits looking beyond questioning for factual basis)
State v. Anderson, 494 N.W.2d 876 (Minn. 1993) (intent to damage inferred from circumstances)