Francis v. State
2013 Minn. LEXIS 224
| Minn. | 2013Background
- Francis seeks postconviction relief from convictions for M.P. shooting and P.R. death; petition denied as time-barred and not saved by exceptions.
- Francis’s 2012 petition argues newly discovered grand jury information shows racial exclusion in Hennepin County grand juries.
- District court denied relief under Minn. Stat. § 590.01, subd. 4(a) as time-barred and under 4(b)(2) for newly discovered-evidence; also deemed Knaffla-barred.
- Court of appeals affirmed time-bar and denied relief, concluding no applicable exception to the two-year limit.
- Francis challenges whether the interests-of-justice exception (4(b)(5)) supports review and whether the newly-discovered-evidence exception (4(b)(2)) was misapplied.
- The court holds the petition is time-barred under § 590.01, subd. 4(a)(2) and fails to satisfy the interests-of-justice exception.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the petition is timely or barred by § 590.01, 4(a). | Francis contends 4(a) time bar should be tolled. | State contends petition untimely under 4(a). | Time-bar upheld; petition untimely. |
| Whether the interests-of-justice exception (4(b)(5)) permits review of an otherwise time-barred petition. | Francis contends 4(b)(5) applies given new information and counsel issues. | State asserts he fails to satisfy 4(b)(5). | Frustrated by failure to meet 4(b)(5); not reviewable. |
| Whether the court properly treated Francis’s claims under 4(b)(2) or 4(b)(5). | Francis relies on 4(b)(5) if 4(b)(2) not satisfied. | Court could apply 4(b)(2) or 4(b)(5); outcome hinges on 4(b)(5) here. | Even under 4(b)(2), petition fails; 4(b)(5) not satisfied. |
Key Cases Cited
- Gassler v. State, 787 N.W.2d 575 (Minn.2010) (factors for interests-of-justice exception; no rigid test)
- Carlton v. State, 816 N.W.2d 590 (Minn.2012) (Gassler factors not always required; discretion varies by case)
- Rickert v. State, 795 N.W.2d 236 (Minn.2011) (timing of transcript access; factors in interests-of-justice)
- Francis I, 729 N.W.2d 584 (Minn.2007) (reaffirmed convictions; describes background and procedural posture)
- Francis II, 781 N.W.2d 892 (Minn.2010) (addressed timing and Knaffla outcomes in prior petitions)
- Knaffla, 309 Minn. 246, 243 N.W.2d 737 (Minn.1976) (finality doctrine; collateral-relief bar for failed direct appeals)