Jacob Stephen Brown v. State of Minnesota
2015 Minn. LEXIS 273
| Minn. | 2015Background
- Brown pleaded guilty in 1988 to first-degree murder of Larson and attempted first-degree murder of M.R.; district court imposed consecutive life and 130-month sentences.
- Brown has filed multiple postconviction petitions; this is his fifth.
- The postconviction court dismissed the petition as time-barred under Minn. Stat. § 590.01, subd. 4(a).
- Brown sought relief arguing his pleas were not knowing, voluntary, and intelligent, based on four documents presented as newly discovered evidence.
- Brown contends exceptions apply: mental disease, newly discovered evidence, and interests of justice.
- Court affirms: none of the exceptions permit consideration outside the two-year window; petition is time-barred.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Brown's petition was timely under §590.01,4(a). | Brown | State | Time-barred; no timely filing raiseable under exceptions. |
| Whether mental-disease exception applies. | Brown asserts mental illness precluded timely assertion | State argues lack of diagnosed mental disease during limitations period | Not satisfied; no evidence Brown had mental illness during 2005-2007 window. |
| Whether newly discovered evidence exception applies. | Brown claims four documents show innocence | State argues insufficient to prove actual innocence by clear and convincing evidence | Not satisfied; four documents do not establish clear and convincing innocence. |
| Whether interests-of-justice exception applies. | Brown alleges discovery issues and lost records justify outside-window review | State maintains no exceptional injustice demonstrated | Not satisfied; no basis shown to invoke §590.01,4(b)(5). |
Key Cases Cited
- Brown v. State (Brown I), 449 N.W.2d 180 (Minn. 1989) (pleas supported by record; side agreement not sufficient to withdraw plea)
- Brown v. State (Brown II), 481 N.W.2d 852 (Minn. 1992) (no mental incompetence proven for valid plea)
- Brown v. State (Brown III), 746 N.W.2d 640 (Minn. 2008) (procedural bar under Knaffla; no relief for involuntary pleas)
- Sanchez v. State, 816 N.W.2d 550 (Minn. 2012) (interests-of-justice exception limited to exceptional cases)
- Riley v. State, 819 N.W.2d 162 (Minn. 2012) (abuse-of-discretion standard; limits on postconviction review)
- State v. Knaffla, 309 Minn. 246, 243 N.W.2d 737 (1976) (rule of preclusion of meritless successive petitions)