Hooper v. State, 838 N.W.2d 775

Background

In 1998 Ann Prazniak was found murdered; Brian Hooper was tried, convicted by a jury of three counts of first-degree murder, and sentenced to concurrent life terms. Hooper exhausted direct appeal and two prior postconviction petitions.
Hooper’s third postconviction petition (filed 2011) raised multiple claims: newly discovered evidence that Chalaka Lewis confessed (via A.A.), alleged recantations by trial witnesses (L.J., C.B., C.K.), a Brady nondisclosure/payoff claim, and that the trial judge’s law clerk dissuaded a defense witness (T.E.) from testifying.
The postconviction court held an evidentiary hearing on some claims (A.A./Lewis confession and L.J. recantation) and summarily denied others as procedurally barred (Knaffla) or meritless; it found A.A. not credible and L.J.’s recantation not genuine.
The State did not press timeliness (Minn. Stat. §590.01, subd. 4(a)) on appeal; the Supreme Court concluded that the statutory filing deadline is not jurisdictional and the State waived the argument.
The Supreme Court affirmed denial of the third petition: (1) Lewis-confession evidence failed the Rainer test (doubtful/cumulative); (2) L.J.’s recantation failed Larrison (credibility); (3) alleged law-clerk interference was harmless because testimony substance was admitted through police testimony; and (4) many claims were Knaffla-barred (previously litigated) including the Brady claim.

Issues

Issue	Hooper's Argument	State's Argument	Held
Whether §590.01 subd. 4(a) time limit is jurisdictional/was waived	Subdivision 4(a) should be treated as jurisdictional or at least considered; petition filed late but merits should be reached	State did not press timeliness on appeal (waived)	Time limit is nonjurisdictional; State waived timeliness; court reached merits
Whether newly discovered evidence (Lewis’s alleged confession via A.A.) warranted a new trial under Rainer	A.A.’s affidavit/letter (2009) shows Lewis confessed; qualifies as newly discovered evidence that could exonerate Hooper	Evidence was doubtful, vague, could have been discovered earlier, and was cumulative/impeaching	Denied: A.A. not credible; evidence failed Rainer (particularly prong 3: not credible/doubtful)
Whether L.J.’s recantation warranted new trial under Larrison	L.J. now recants his trial testimony that Hooper admitted the killing	State emphasizes prior consistent grand-jury/trial testimony and L.J.’s post-trial convictions undermining credibility	Denied: postconviction court not reasonably well satisfied recantation was genuine; credibility findings upheld
Whether law-clerk interference, Brady/payoff, and other claims merit relief or removal of district judges	Law-clerk dissuasion deprived Hooper of witnesses/right to present defense; C.B./C.K. recantations and alleged State promises withheld (Brady); entire Fourth Judicial District must be recused	Clerk interference, even if true, was harmless because substance of testimony was admitted; many claims are Knaffla-barred; recusal of whole bench unsupported	Denied: interference harmless beyond reasonable doubt; Brady and recantation claims procedurally barred; motion to remove judges denied

Key Cases Cited

Hooper v. State, 620 N.W.2d 31 (Minn. 2000) (affirming convictions and prior postconviction denial)
Hooper v. State, 680 N.W.2d 89 (Minn. 2004) (affirming denial of second postconviction petition)
State v. Knaffla, 243 N.W.2d 737 (Minn. 1976) (procedural bar rule for claims that could have been raised earlier)
Carlton v. State, 816 N.W.2d 590 (Minn. 2012) (statutory postconviction time limits are nonjurisdictional and subject to waiver)
Rainer v. State, 566 N.W.2d 692 (Minn. 1997) (four-part test for newly discovered evidence)
Larrison v. United States, 24 F.2d 82 (7th Cir. 1928) (test for new trial based on false testimony)
Brady v. Maryland, 373 U.S. 83 (U.S. 1963) (prosecution duty to disclose exculpatory evidence)
Chambers v. Mississippi, 410 U.S. 284 (U.S. 1973) (due-process right to present witnesses in one’s defense)