Brian Keith Hooper v. State of Minnesota, 888 N.W.2d 138

Background

In 1998 Ann Prazniak was found murdered; evidence at trial included fingerprints belonging to Hooper, beige packing tape and Christmas lights like those used to bind the body, and testimony that Hooper admitted being in the victim’s apartment and that several witnesses heard or reported confessions.
Hooper was convicted of three counts of first‑degree murder and sentenced to concurrent life terms; this Court affirmed the convictions in 2000.
Hooper filed multiple postconviction petitions raising witness recantations (C.K., C.B., L.J., L.F.) and challenges to accomplice testimony (C.L.); prior petitions were litigated in Hooper I, Hooper II, and Hooper III.
This fourth petition (filed July 16, 2015) relied principally on a new affidavit from L.F. recanting her testimony that Hooper confessed, plus investigator affidavits about attempts to locate L.F. earlier.
The postconviction court summarily denied the petition as untimely under the 2‑year postconviction statute of limitations and as procedurally barred under the Knaffla rule for claims previously raised or known.

Issues

Issue	Hooper's Argument	State's Argument	Held
Timeliness under 2‑year statute	L.F.’s 2013 recantation is newly discovered; petition filed within two years of claim arising	Petition filed long after the July 31, 2007 deadline for pre‑2005 final convictions; claimant knew or should have known earlier	Petition untimely; no newly discovered‑evidence exception — Hooper should have known earlier
Interests‑of‑justice exception to statute of limitations	Delay was justified by inability to obtain L.F.’s recantation until 2013; combined recantations show innocence	Hooper lacked due diligence (large gaps in searching for L.F.); exception requires an injustice causing delay, not mere petition merits	Exception not satisfied; no rare/exceptional injustice shown
Procedural bar (Knaffla) for previously raised claims	Previously raised recantations and corroboration with L.F.’s recantation warrant reconsideration in interests of justice	Claims were known or should have been known earlier; prior decisions resolved credibility and barred relitigation	Knaffla bars the previously raised claims; interests‑of‑justice exception not met because claims lack substantive merit
Substantive merit for new‑trial claim based on recanted testimony	Combined recantations render prior testimonial fabrications and would likely change jury outcome	Even without some confession witnesses, strong corroborating evidence (fingerprints, tape, lights, admissions, L.J.’s upheld testimony) would support conviction	Petition lacks substantive merit; even without recanted testimony jury likely would not have reached a different result

Key Cases Cited

State v. Hooper, 620 N.W.2d 31 (Minn. 2000) (direct‑appeal decision affirming convictions)
State v. Hooper, 680 N.W.2d 89 (Minn. 2004) (postconviction review addressing recantation claims)
State v. Hooper, 838 N.W.2d 775 (Minn. 2013) (postconviction review resolving earlier recantation and credibility issues)
State v. Knaffla, 243 N.W.2d 737 (Minn. 1976) (procedural bar for claims known or raisable on direct appeal)
Bobo v. State, 820 N.W.2d 511 (Minn. 2012) (standards for summary denial of postconviction petition)
Ferguson v. State, 645 N.W.2d 437 (Minn. 2002) (test for new trial where testimony proved false)