Jetaun Helen Wheeler v. State of Minnesota, 2017 Minn. App. LEXIS 14

Wheeler was charged with second-degree intentional murder after a body was found in her freezer and two of her children later told therapists they witnessed her and a friend harm the victim.
The district court encouraged counsel to negotiate a resolution because of the trauma to the children; initial offers included manslaughter (defense) and unintentional second-degree murder (state).
Nine days before trial the court emailed that it would not accept a straight plea to manslaughter and suggested unintentional second-degree murder was more realistic; no plea was reached immediately.
After trial began and before the children testified, Wheeler agreed to plead guilty to aiding and abetting unintentional second-degree murder with an agreed sentencing range of 128–180 months; the court later sentenced her to 172 months.
Wheeler filed a postconviction petition alleging the court had improperly inserted itself into plea negotiations (including an affidavit from trial counsel referencing an off‑record law‑clerk conversation); the district court denied relief and an evidentiary hearing, and the Court of Appeals affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the postconviction court abused its discretion by denying an evidentiary hearing	Wheeler: affidavit and allegations created disputed material facts warranting a hearing	State: record (emails, plea colloquy) conclusively shows no need for a hearing; allegations are vague/argumentative	No abuse of discretion; denial affirmed
Whether the district court impermissibly participated in plea negotiations, invalidating the plea	Wheeler: court encouraged/monitored negotiations, suggested acceptable plea terms, and pressured parties so plea was induced by court involvement	State: court only monitored, informed counsel of unacceptable proposals, and made no sentencing promises; plea was voluntary	Court did not impermissibly participate; plea was valid and voluntary

Morrow v. State, 886 N.W.2d 204 (Minn. 2016) (standard of review for denial of postconviction relief and evidentiary hearings)
Riley v. State, 819 N.W.2d 162 (Minn. 2012) (postconviction review principles)
Erickson v. State, 842 N.W.2d 314 (Minn. 2014) (fact findings and questions of law review standards)
Griffin v. State, 883 N.W.2d 282 (Minn. 2016) (abuse of discretion defined in postconviction context)
State v. Caldwell, 803 N.W.2d 373 (Minn. 2011) (when an evidentiary hearing is required)
Bobo v. State, 820 N.W.2d 511 (Minn. 2012) (presumption of truth for allegations when assessing need for hearing)
State v. Raleigh, 778 N.W.2d 90 (Minn. 2010) (accuracy, voluntariness, and intelligence required for plea validity)
State v. Johnson, 156 N.W.2d 218 (Minn. 1968) (district court’s proper and improper roles in plea bargaining)
Melde v. State, 778 N.W.2d 376 (Minn. App. 2010) (reversible error where court promised a specific sentence to induce a plea)
Anyanwu v. State, 681 N.W.2d 411 (Minn. App. 2004) (court impermissibly imposed sentence over prosecutor objection)
Ecker v. State, 524 N.W.2d 712 (Minn. 1994) (levels of coercion that invalidate pleas)