Edbert Neal Williams v. State of Minnesota, 2015 Minn. LEXIS 502

In 1996 Edbert Williams was tried and convicted of first-degree premeditated murder (Genelda Campeau) and attempted first-degree murder (S.C.), based largely on S.C.’s identification and testimony from a jailhouse informant, Darryl Irby.
Williams received life plus a consecutive 180-month sentence; this Court affirmed on direct appeal in State v. Williams, 593 N.W.2d 227 (Minn. 1999).
In 2003 Williams filed a first postconviction petition asserting Iry’s recantation and suggesting an alternate suspect (G.B.); an evidentiary hearing was held, Irby recanted his recantation, and the petition was denied and affirmed on appeal (Williams II, 692 N.W.2d 893).
In 2013 Williams filed a second postconviction petition asserting ineffective assistance of trial counsel (failure to investigate G.B.; preventing Williams from testifying) and ineffective assistance of appellate counsel (failure to raise the trial-counsel claim on direct appeal).
The postconviction court denied the 2013 petition without an evidentiary hearing, finding the claims untimely under the 2-year statute and procedurally barred by the Knaffla rule; Williams appealed.
The Supreme Court affirmed, holding Williams’s claims were procedurally barred (Knaffla) and that he forfeited a new "interests of justice" argument by raising it for the first time on appeal.

Issue	Williams' Argument	State's Argument	Held
Whether Williams was entitled to an evidentiary hearing on ineffective-assistance claims	Postconviction relief and hearing required to develop facts (investigation of G.B.; counsel prevented him testifying)	Claims are procedurally barred (Knaffla) and untimely; no hearing required	Denied — no abuse of discretion; claims Knaffla-barred, so no evidentiary hearing warranted
Whether claims are Knaffla-barred or untimely	Could not raise earlier due to counsel and alleged mental illness; appellate- counsel claim could not be raised earlier because it required extra-record facts	Williams knew or could have known claims by 2003 (and appellate-claim by direct appeal); counsel choice didn’t prevent filing pro se; mental illness not shown to excuse delay	Held Knaffla bars both trial- and appellate-counsel claims; mental-illness excuse not supported by record
Whether Williams preserved an interests-of-justice exception (Beecroft)	Asserts freestanding interests-of-justice claim should excuse procedural default	Argument forfeited because raised first on appeal; also insufficient to show excuse for previous inaction	Forfeited; Court declines to consider it on appeal

State v. Knaffla, 309 Minn. 246, 243 N.W.2d 737 (Minn. 1976) (establishing the rule barring claims that were or could have been raised earlier)
State v. Williams, 593 N.W.2d 227 (Minn. 1999) (direct appeal affirming convictions)
Williams v. State, 692 N.W.2d 893 (Minn. 2005) (resolving Williams’s first postconviction petition)
State v. Beecroft, 813 N.W.2d 814 (Minn. 2012) (plurality discussing interests-of-justice exception)
Caldwell v. State, 853 N.W.2d 766 (Minn. 2014) (standard of review for evidentiary-hearing decisions)
Buckingham v. State, 799 N.W.2d 229 (Minn. 2011) (postconviction petitioner not entitled to evidentiary hearing when claims are Knaffla-barred)