Buckingham v. State, 799 N.W.2d 229

Buckingham and Hatcher threatened Ricardo Walker outside Gabby’s Bar; shots fired from a white SUV at Walker’s minivan, leaving Walker fatally wounded.
Walker provided a dying declaration linking Hatcher and Buckingham to the shooting.
A jury convicted Buckingham as an accomplice to first-degree premeditated murder and to several related offenses; he received life imprisonment without parole for the murder conviction.
On direct appeal, Buckingham challenged custodial statements, sufficiency of the evidence, an alleged sentencing error, and prosecutorial misconduct; the convictions were affirmed and the sentence modified.
Buckingham then sought postconviction relief alleging custodial-statement issues, an incomplete psychological evaluation, an erroneous accomplice-liability instruction, and ineffective trial counsel.
The postconviction court denied relief, holding that most claims were procedurally barred under Knaffla; Buckingham appealed the denial.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Buckingham’s custodial statements were admissible notwithstanding Scales, Sixth Amendment, involuntariness, and Miranda concerns	Buckingham argues Scales violations, absence of counsel, involuntariness, and Miranda issues.	State argues the issues are barred under Knaffla and closely related to direct-appeal arguments.	Knaffla-barred; issues related to custodial statements are not reviewable.
Whether the district court relied on an incomplete psychological evaluation to determine competence	Buckingham asserts incomplete evaluation affected competency.	State asserts evaluation completed pre-direct appeal; no new facts require hearing.	Knaffla-barred; no grounds to revisit with new evidence.
Whether the jury instruction on accomplice liability was reversible error	Buckingham contends the instruction relieved the State of proving all elements beyond a reasonable doubt.	State contends issue could have been raised on direct appeal; unexcused delay bars review.	Knaffla-barred; instructional error claims not raised on direct appeal are barred.
Whether Buckingham received ineffective assistance of trial counsel	Buckingham argues trial counsel failed to challenge custodial statements and related issues; claims based on the trial record.	State argues postconviction is not appropriate to develop such claims when based on the trial record.	Knaffla-barred; no evidentiary hearing necessary as claims are barred.

Knaffla v. State, 309 Minn. 246, 243 N.W.2d 737 (Minn. 1976) (establishes procedural bar for postconviction relief after direct appeal)
White v. State, 711 N.W.2d 106 (Minn. 2006) (grounds for Knaffla applicability; statutory bar message)
Wright v. State, 765 N.W.2d 85 (Minn. 2009) (interests-of-justice exception to Knaffla; merit and lack of delay)
Reed v. State, 793 N.W.2d 725 (Minn. 2010) (abuse-of-discretion standard in postconviction review; evidentiary hearing considerations)
Barnes v. State, 768 N.W.2d 359 (Minn. 2009) (postconviction evidentiary hearings to develop ineffective-assistance claims)
Dobbins v. State, 788 N.W.2d 719 (Minn. 2010) (denial of evidentiary hearing reviewed for abuse of discretion)