916 N.W.2d 502
Minn.2018Background
- Joseph Haywood Campbell, convicted of first-degree premeditated murder for the benefit of a gang, was sentenced to life without release; conviction affirmed on direct appeal.
- At trial witnesses placed Campbell near the victim, wearing a distinctive jacket and mask; another witness (D.M.) corroborated key facts.
- After direct appeal, Campbell filed a postconviction petition alleging (1) a key witness L.J. recanted, (2) ineffective assistance of trial counsel for failing to impeach witnesses, and (3) a Brady violation—prosecutor’s nondisclosure of favorable treatment to witness I.R.
- The postconviction court denied the petition without an evidentiary hearing, finding the recantation proffer unreliable, the ineffective-assistance claim Knaffla-barred, and any Brady evidence immaterial.
- Campbell appealed; the Minnesota Supreme Court reviewed de novo legal issues and for abuse of discretion factual determinations related to denial of an evidentiary hearing.
Issues
| Issue | Plaintiff's Argument (Campbell) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Whether alleged recantation by L.J. entitles Campbell to new trial or evidentiary hearing | L.J. recanted trial testimony; recantation warrants hearing or new trial | Proffered evidence is hearsay, lacks indicia of trustworthiness; insufficient under Larrison | Denied—proffer insufficient to satisfy first Larrison prong or to warrant hearing |
| Whether ineffective-assistance claim is procedurally barred under Knaffla | Claim could not be raised earlier / requires further development | Claim was known from trial record and thus should have been raised on direct appeal (Knaffla) | Denied as Knaffla-barred; record already showed counsel’s trial actions |
| Whether nondisclosure of favorable treatment to witness I.R. violated Brady | I.R. received favorable treatment for testimony; State suppressed impeaching evidence | Even if undisclosed, the evidence was not material to the outcome | Denied—Brady not shown because additional impeachment was cumulative: I.R. was already impeached and D.M. corroborated key testimony |
| Whether postconviction court abused discretion by refusing evidentiary hearing | A hearing is necessary to test recantation and Brady allegations | The petition’s proffers lacked trustworthiness or materiality; no hearing required | Denied—no abuse of discretion in summary dismissal without hearing |
Key Cases Cited
- Larrison v. United States, 24 F.2d 82 (7th Cir. 1928) (test for new trial based on alleged false or recanted witness testimony)
- Brady v. Maryland, 373 U.S. 83 (1963) (prosecution must disclose materially favorable evidence)
- United States v. Bagley, 473 U.S. 667 (1985) (materiality standard for Brady; "reasonable probability" standard)
- State v. Knaffla, 309 Minn. 246 (Minn. 1976) (procedural bar for issues that could have been raised on direct appeal)
- McKenzie v. State, 872 N.W.2d 865 (Minn. 2015) (hearsay insufficient to satisfy first Larrison prong)
- Giglio v. United States, 405 U.S. 150 (1972) (plea bargains for testimony are impeachment material that must be disclosed)