Chaun Dubae Carridine v. State of Minnesota, 2015 Minn. LEXIS 384

Background

In 2007 Chaun Dubae Carridine shot and killed Lorenzo Guffie; a jury convicted Carridine of first‑degree premeditated murder and he was sentenced to life. The conviction was affirmed on direct appeal.
Carridine filed a pro se postconviction petition raising multiple claims: evidentiary error (impeachment evidence), prosecutorial misconduct, ineffective assistance of trial and appellate counsel, and newly discovered evidence based on affidavits from De’Angelo Madison, Eric Hawkins, and John Hill.
The postconviction court summarily denied all claims except the newly discovered‑evidence claim based on Madison’s and Hill’s affidavits; it held an evidentiary hearing on those affidavits and then denied relief, finding the witnesses not credible.
The court concluded many claims were procedurally barred because they were based on the trial record or had been raised (or could have been raised) on direct appeal under Knaffla/Minn. Stat. § 590.01.
The court also denied the ineffective‑assistance‑of‑appellate‑counsel claim on the merits, finding Carridine failed to satisfy Strickland: alleged appellate omissions were either meritless or related to trial strategy and would not likely have changed the outcome.
On the newly discovered evidence claim, the postconviction court found Madison and Hill’s testimony doubtful and conflicting, so the Rainer requirements (noncumulative, not doubtful, and likely to produce acquittal) were not met.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether postconviction court erred in summarily denying claims based on trial record (impeachment evidence, prosecutorial misconduct, ineffective trial counsel, Hawkins affidavit)	Carridine argued these claims merited postconviction relief	State argued claims were Knaffla‑barred because they were raised or could have been raised on direct appeal	Court held claims were procedurally barred and summary denial proper
Whether appellate counsel was ineffective for failing to raise ineffective‑trial‑counsel claims on appeal	Carridine alleged appellate counsel should have raised several trial‑counsel failures (investigation, subpoenas, objections)	State argued these allegations largely concern trial strategy and lack proof of prejudice under Strickland	Court held petition failed Strickland first and second prongs; summary denial proper
Whether appellate counsel was ineffective for not raising additional prosecutorial‑misconduct claims	Carridine asserted prosecutor presented perjured testimony and discovery violations	State argued additional misconduct claims lacked merit and appellate counsel need not raise all issues	Court held alleged misconduct lacked merit; appellate counsel’s choices were reasonable
Whether newly discovered evidence (Madison, Hill) warranted a new trial under Rainer	Carridine claimed affidavits would exonerate or produce more favorable result	State and postconviction court argued witnesses were not credible, testimony doubtful and conflicting	Court held Rainer prongs (noncumulative/doubtful and probable impact) not met; relief denied

Key Cases Cited

Strickland v. Washington, 466 U.S. 668 (1984) (two‑prong test for ineffective assistance of counsel requiring deficient performance and prejudice)
State v. Knaffla, 243 N.W.2d 737 (Minn. 1976) (claims known at direct appeal barred on subsequent postconviction)
Rainer v. State, 566 N.W.2d 692 (Minn. 1997) (four‑part test for newly discovered evidence to obtain a new trial)
Nissalke v. State, 861 N.W.2d 88 (Minn. 2015) (standards for pleading ineffective‑assistance claims in postconviction petitions)
Hokanson v. State, 821 N.W.2d 340 (Minn. 2012) (petition must allege facts that if proven would entitle petitioner to relief)
Miles v. State, 840 N.W.2d 195 (Minn. 2013) (postconviction court’s credibility findings are given deference)