Frank Duane Lussier v. State of Minnesota
2014 Minn. LEXIS 455
| Minn. | 2014Background
- Lussier killed his wife on March 17, 2003 and pled guilty to first-degree murder while committing domestic abuse.
- The district court admitted the grand-jury transcript to supplement the factual basis for the plea with Lussier's agreement to the court’s summary of witnesses’ anticipated testimony.
- Lussier submitted a statement indicating he did not intend to kill, but to kill himself, and the plea hearing relied on this to some extent.
- Lussier did not file a direct appeal after sentencing.
- In 2011 he moved to withdraw the plea, arguing the plea lacked an accurate, intelligent, or voluntary basis and that the factual basis was insufficient.
- He subsequently filed a second postconviction petition alleging the plea was inaccurate and that his first postconviction counsel provided ineffective assistance by not requesting an evidentiary hearing; the postconviction court denied without an evidentiary hearing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Lussier’s guilty-plea challenge is procedurally barred. | Lussier argues the plea lacks a valid factual basis. | State contends the issue was previously decided and barred by Knaffla. | Procedurally barred under Knaffla. |
| Whether postconviction counsel’s failure to request an evidentiary hearing was ineffective. | Lussier asserts undisputed facts could have supported an evidentiary hearing. | State argues disputed facts were immaterial to the plea's accuracy and no hearing was needed. | No, failed Strickland prongs; hearing not required. |
Key Cases Cited
- State v. Knaffla, 309 Minn. 246 (Minn. 1976) (Knaffla rule: claims not raised on direct appeal are barred in a postconviction petition)
- Jones v. State, 671 N.W.2d 743 (Minn. 2003) (extends Knaffla to postconviction petitions)
- Buckingham v. State, 799 N.W.2d 229 (Minn. 2011) (recognizes Knaffla bar even when exceptions exist)
- Reed v. State, 793 N.W.2d 725 (Minn. 2010) (abuse of discretion standard for postconviction relief)
- McDonough v. State, 827 N.W.2d 423 (Minn. 2013) (standard for evaluating postconviction evidence and requests)
- Leake v. State, 737 N.W.2d 531 (Minn. 2007) (evidentiary hearing requirements in postconviction proceedings)
- Fratzke v. State, 450 N.W.2d 101 (Minn. 1990) (when an evidentiary hearing is unnecessary)
- Kelsey v. State, 298 Minn. 531 (Minn. 1974) (adequacy of factual basis for a guilty plea)