Derrick Trevor Griffin v. State of Minnesota, 2016 Minn. LEXIS 484

In 2012 a Hennepin County jury convicted Derrick Trevor Griffin of two counts of first‑degree murder for the killing of one victim; he received life without release for premeditated murder.
This court affirmed Griffin’s convictions on direct appeal in State v. Griffin, 834 N.W.2d 688 (Minn. 2013).
Griffin filed a timely postconviction petition (2015) alleging ineffective assistance of trial and appellate counsel and certain double‑jeopardy and multiple‑punishment/statutory‑violation claims.
The postconviction court summarily denied relief; Griffin appealed that denial.
Key contested evidentiary fact: an out‑of‑court statement by Griffin’s wife (K.G.) identifying Griffin near a bar shortly before the murder; Griffin argues counsel should have objected.
Griffin also argued counsel should have raised violations of Minn. Stat. § 609.035 and constitutional double jeopardy protections; he further alleged appellate counsel was ineffective for not raising trial‑counsel claims on direct appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Trial counsel ineffective for not objecting to K.G.’s out‑of‑court statement	Griffin: counsel erred by failing to object to hearsay/unreliable statement	State: admission was proper; objection would have been overruled	Denied — counsel’s failure to object was objectively reasonable (Griffin I had already upheld admission)
Trial counsel ineffective for not raising violations of Minn. Stat. § 609.035 (multiple punishment)	Griffin: convictions/punishments violate § 609.035/double jeopardy	State: only one prosecution and one sentence; § 609.035 and Double Jeopardy do not apply	Denied — record shows only one prosecution/sentence; no double‑jeopardy or § 609.035 violation
Whether postconviction claims are Knaffla‑barred (procedural default)	Griffin: interests‑of‑justice exception applies where same attorney represented him at trial and on appeal	State: Knaffla bars claims that could have been raised on direct appeal	Court assumed exception could apply but resolved claims on merits; did not decide Knaffla exception question
Appellate counsel ineffective for not raising trial‑counsel claims on direct appeal	Griffin: appellate counsel failed to raise ineffective‑assistance‑of‑trial‑counsel	State: appellate counsel not ineffective where trial counsel was not ineffective	Denied — appellate claim fails because underlying trial‑counsel claims lack merit

State v. Griffin, 834 N.W.2d 688 (Minn. 2013) (direct‑appeal decision upholding admission of K.G.’s statement)
Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two‑part ineffective assistance standard)
State v. Chavarria‑Cruz, 839 N.W.2d 515 (Minn. 2013) (Double Jeopardy/§ 609.035 analysis)
State v. Schmidt, 612 N.W.2d 871 (Minn. 2000) (scope of double jeopardy and § 609.035 protections)
Fields v. State, 733 N.W.2d 465 (Minn. 2007) (appellate counsel ineffective‑assistance claim must predicate on proven trial‑counsel ineffectiveness)
State v. Jama, 756 N.W.2d 107 (Minn. App. 2008) (discussing fairness exception where same counsel handled trial and appeal)
State v. Knaffla, 243 N.W.2d 737 (Minn. 1976) (procedural default rule for claims not raised on direct appeal)