Joel Marvin Munt v. State of Minnesota, 880 N.W.2d 379

Joel Munt was convicted after a bifurcated jury trial of first-degree murder and related offenses for killing his former wife and kidnapping their three children; convictions were affirmed on direct appeal (State v. Munt).
Munt filed a pro se postconviction petition on August 3, 2015, claiming (1) erroneous jury instructions on circumstantial evidence leading to insufficient evidence and (2) that his life-without-parole sentence violates Miller v. Alabama when applied to adults.
The postconviction court summarily denied relief as untimely and meritless; this Court determined Munt’s petition was in fact timely but proceeded to review procedural and substantive grounds.
The court held the jury-instruction claims were procedurally barred under the Knaffla rule because they were known or should have been known at the time of direct appeal and Munt did not meet recognized exceptions.
The court held Miller is limited to juvenile offenders and does not apply to a 35-year-old defendant; an equal-protection argument to extend Miller to adults failed because adults and juveniles are not similarly situated for sentencing purposes.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Jury instruction on circumstantial evidence / sufficiency	Munt: trial court gave incorrect circumstantial-evidence instruction; correct standard would show insufficiency	State: claim was known at trial/direct appeal and is therefore procedurally barred under Knaffla; no exception applies	Court: procedurally barred; no Knaffla exception satisfied, so postconviction denial affirmed
Application of Miller v. Alabama to life without parole	Munt: Miller should apply to adults or equal-protection requires extending Miller’s rule to him	State: Miller applies only to juveniles; adults are not similarly situated	Court: Miller is limited to juveniles; claim meritless — denial affirmed

State v. Munt, 831 N.W.2d 569 (Minn. 2013) (direct-appeal decision affirming convictions)
State v. Knaffla, 243 N.W.2d 737 (Minn. 1976) (postconviction bar for claims known at time of direct appeal)
White v. State, 711 N.W.2d 106 (Minn. 2006) (explaining Knaffla rule application)
McKenzie v. State, 754 N.W.2d 366 (Minn. 2008) (errors observable at trial must be raised on direct appeal)
Colbert v. State, 870 N.W.2d 616 (Minn. 2015) (recognizing limited exceptions to Knaffla)
Miller v. Alabama, 132 S. Ct. 2455 (U.S. 2012) (holding mandatory life-without-parole unconstitutional for juvenile offenders)
Montgomery v. Louisiana, 136 S. Ct. 718 (U.S. 2016) (holding Miller announced a substantive rule that is retroactive)