Johnson v. State
2011 Minn. LEXIS 465
| Minn. | 2011Background
- Johnson was indicted in 1999 on first-degree murder (involving kidnapping), second-degree murder, and kidnapping.
- In 2000, the State amended count one to aiding and abetting first-degree murder; Johnson pled guilty to amended count one and count two.
- The plea agreement conditioned Johnson’s sentence on providing useful information about the murder; failure to provide such information led to a life sentence with parole after 30 years.
- The court sentenced Johnson in 2000 to life with parole after 30 years on amended count one, after the State found no useful information.
- Johnson filed a postconviction petition in 2001 which the district court and this Court affirmed; Johnson later sought relief under Minn. R. Crim. P. 27.03 in 2010.
- The district court corrected the sentence under Rule 27.03 but the merits of the conviction were challenged as untimely under Minn. Stat. § 590.01.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Rule 27.03 motion can challenge conviction | Johnson | State | Motion not proper vehicle to challenge conviction; treated as postconviction relief |
| Timeliness of postconviction petition under §590.01 | Johnson | State | Untimely under § 590.01, subd. 4; no applicable exception |
| Application of Knaffla/time-bar to claims | Johnson | State | Claims barred by time bar; exceptions not satisfied |
Key Cases Cited
- State v. Rourke, 773 N.W.2d 913 (Minn. 2009) (de novo review for procedural rule interpretation)
- State v. Barrett, 694 N.W.2d 783 (Minn. 2005) (statutory interpretation of procedural rules)
- Mendota Golf, LLP v. City of Mendota Heights, 708 N.W.2d 162 (Minn. 2006) (substance-over-form approach to pleadings)
- Reed v. State, 793 N.W.2d 725 (Minn. 2010) (Knaffla principles and postconviction pleading requirements)
- King v. State, 649 N.W.2d 149 (Minn. 2002) (Knaffla-related disclosure about claims asserted)
- State v. Knaffla, 309 Minn. 246, 243 N.W.2d 737 (Minn. 1976) (default rule barring claims not raised on direct appeal)
- Ortiz v. Gavenda, 590 N.W.2d 119 (Minn. 1999) (exceptions to time bar for postconviction relief)
- Stewart v. State, 764 N.W.2d 32 (Minn. 2009) (time-bar analysis and postconviction relief standards)