Kevin Terrance Hannon v. State of Minnesota, 889 N.W.2d 789

In 1999 Kevin Terrance Hannon killed his girlfriend; physical and DNA evidence (bloodstained shirt with victim and predominant wearer DNA) linked him to the crime.
Hannon was convicted at a first trial, that conviction was reversed on appeal (State v. Hannon, 636 N.W.2d 796), retried, convicted of first‑degree murder during a kidnapping, and sentenced to life without release under Minn. Stat. § 609.106, subd. 2(2); conviction affirmed on direct appeal (State v. Hannon, 703 N.W.2d 498).
Hannon filed multiple postconviction petitions: first (denied after hearing; affirmed, 752 N.W.2d 518) and second (denied as untimely; affirmed, 781 N.W.2d 887).
In Sept. 2015 Hannon filed a voluminous third postconviction petition raising 12 categories of claims (e.g., sentencing error, incompetence, ineffective assistance, judicial bias, Brady/prosecutorial misconduct, false DNA testimony, actual innocence).
The postconviction court denied the third petition without an evidentiary hearing: it found the sentencing claim meritless (sentence authorized by § 609.106) and all other claims untimely under the two‑year statute of limitations in Minn. Stat. § 590.01, subd. 4.

Issue	Hannon's Argument	State's Argument	Held
Validity of life‑without‑release sentence	Sentence exceeds § 609.185; max is simply life	Sentence authorized by § 609.106, subd. 2(2) for murder during kidnapping	Sentence authorized; claim meritless
Timeliness of most postconviction claims under § 590.01	Claims not time‑barred; many purportedly rely on newly discovered evidence	Claims were filed ~8 years after finality; statutory 2‑year limit bars them absent exceptions	Claims untimely; exceptions do not apply
Newly discovered evidence exception invoked (subd. 4(b)(2))	DNA and other evidence allegedly newly discovered show false testimony / innocence	Alleged evidence was known or discoverable well before the two‑year window; supporting materials predate 2013	Evidence arose before Sept. 2013; exception fails
Need for evidentiary hearing	Facts and affidavits require live fact‑finding	Claims are legally insufficient or time‑barred; no hearing required	No abuse of discretion in denying hearing; summary denial affirmed

State v. Hannon, 636 N.W.2d 796 (Minn. 2001) (reversed first conviction for Miranda/counsel invocation error)
State v. Hannon, 703 N.W.2d 498 (Minn. 2005) (affirmed second‑trial conviction)
Hannon v. State, 752 N.W.2d 518 (Minn. 2008) (affirming denial of first postconviction petition)
Hannon v. State, 781 N.W.2d 887 (Minn. 2010) (affirming denial of second postconviction petition as untimely)
Rhodes v. State, 875 N.W.2d 779 (Minn. 2016) (standards for postconviction evidentiary hearings and summary denials)
Erickson v. State, 842 N.W.2d 314 (Minn. 2014) (abuse‑of‑discretion standard for postconviction denial)
Brown v. State, 863 N.W.2d 781 (Minn. 2015) (definition of abuse of discretion in postconviction context)
Wilson v. State, 726 N.W.2d 103 (Minn. 2007) (petitioner’s burden to prove entitlement to relief)
Berkovitz v. State, 826 N.W.2d 203 (Minn. 2013) (finality date for conviction tied to certiorari period lapse)
State v. Knaffla, 243 N.W.2d 737 (Minn. 1976) (bar on raising claims in successive postconviction petitions when known earlier)