Carlton v. State
2012 Minn. LEXIS 303
| Minn. | 2012Background
- Carlton was convicted of first-degree premeditated murder and murder during criminal sexual conduct and sentenced to life without release.
- Direct appeal was stayed in 1996 and dismissed in 1997; Carlton did not pursue postconviction relief at that time.
- In August 2010 Carlton, with counsel, filed a petition for postconviction relief alleging improper warrant-based evidence and Spreigl evidence admissions.
- The postconviction court denied as untimely under Minn. Stat. § 590.01, subd. 4(a), and declined to address the merits due to timeliness.
- The court also concluded § 590.01, 4(c) is not jurisdictional and is waivable, and that the State waived timeliness by not raising it.
- On appeal, the Minnesota Supreme Court upheld denial, holding the time limit is a waivable statute of limitations and Carlton failed to show the interests-of-justice exception warranted relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether petition timelinessbars relief | Carlton argues timely filing via 4(b)(5) should waive 4(a) limits. | State contends petition untimely under 4(a) and 4(c) limits. | Time limit not jurisdictional; timely petition not established |
| Whether 4(c) is jurisdictional or waivable | 4(c) should be waivable; equitable tolling may apply. | 4(c) is jurisdictional and not tollable. | Court holdings: 4(c) is not jurisdictional and is waivable |
| Whether interests-of-justice exception allows untimely petition | Delay due to inability to obtain appellate review warrants relief | Delay attributable to Carlton; exception not satisfied | Interests-of-justice exception not met; petition denied on merits timeliness |
| Whether Minnesota Constitution guarantees unlimited right to one substantive review | Right to one substantive review is unlimited under Minnesota Constitution | No unlimited right; time limits may regulate review | Decided as a constitutional question but ultimately held time limit permissible; not unlimited |
Key Cases Cited
- State v. Knaffla, 309 Minn. 246 (Minn. 1976) (establishes right to at least one review by appellate/postconviction court)
- Spann v. State, 704 N.W.2d 486 (Minn. 2005) (limits on waiving appellate rights and purposes of review rights)
- Gassler v. State, 787 N.W.2d 575 (Minn. 2010) (nonfrivolous vs. substantial merit and interests-of-justice factors)
- Rickert v. State, 795 N.W.2d 236 (Minn. 2011) (illustrates application of interests-of-justice factors)
- Holland v. Florida, 560 U.S. 631 (U.S. 2010) (equitable tolling applied to federal habeas; analogue discussion)
- McKane v. Durston, 153 U.S. 684 (U.S. 1894) (courts need not guarantee a right to appeal under due process)
- Spann v. State, 704 N.W.2d 486 (Minn. 2005) (right to one review contextually discussed)
- Deegan v. State, 711 N.W.2d 89 (Minn. 2006) (right to one review may be grounded in Minnesota Constitution; discussed postconviction rights)
- State v. Oman, 261 Minn. 10 (Minn. 1961) (state constitutional interpretation framework)