LaMonte Rydell Martin v. State of Minnesota
865 N.W.2d 282
| Minn. | 2015Background
- LaMonte Rydell Martin was convicted of first-degree premeditated murder and a gang-related offense for a 2006 execution-style killing; he was sentenced to life without parole (LWOR) and his conviction/sentence were affirmed on direct appeal (Martin I).
- Martin filed a postconviction petition alleging two key eyewitnesses (Mack‑Lyneh and Charles Pettis) recanted their trial testimony; this court remanded for an evidentiary hearing to assess those recantations (Martin II).
- At the evidentiary hearing, Pettis invoked his Fifth Amendment privilege through counsel and did not testify; the court allowed the invocation without Pettis personally asserting it on the stand.
- The State introduced strong evidence that Martin orchestrated bribery, threats, and coercion to produce the recantations, including Martin’s guilty plea for bribery in a related witness‑tampering case and testimony that the affidavits were false.
- The postconviction court denied relief: it found the recantations were not genuine (failing the first Larrison prong) and denied Martin’s separate Miller‑based challenge to his LWOR sentence as time‑barred; this appeal affirms those holdings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Validity of Pettis invoking Fifth via counsel at hearing | Pettis’s privilege was invalid absent Pettis personally asserting it under oath; court needed to assess credibility by hearing him testify | Privilege may be validly invoked by counsel where danger of incrimination is obvious; court has discretion | Court did not abuse discretion; invocation valid without Pettis present |
| Court-ordered immunity to compel Pettis to testify | Martin asked court to force testimony by granting immunity so Pettis would be compelled to testify | Immunity statute requires a written prosecutorial request; courts lack authority to grant immunity on defense request | Denial affirmed; court properly refused because statute requires prosecutor request and no misconduct by State shown |
| Witness‑recantation/new‑trial under Larrison | Recantation affidavits establish trial witnesses testified falsely and would warrant new trial | Recantations were products of bribery/coercion; evidence (plea, testimony, letters) shows recantations false and unreliable | Postconviction court did not err: first Larrison prong not met because recantations lacked indicia of trustworthiness; relief denied |
| Miller retroactivity and time‑bar for LWOR challenge | Miller should apply retroactively to juveniles, so Martin’s late petition fits the statute exception | Minnesota precedent holds Miller is not retroactive on collateral review; petition therefore time‑barred | Denied: Miller not retroactive here; petition time‑barred and other claims fail |
Key Cases Cited
- Martin v. State, 773 N.W.2d 89 (Minn. 2009) (direct appeal affirming conviction and LWOR sentence)
- Martin v. State, 825 N.W.2d 734 (Minn. 2013) (remanding for evidentiary hearing on witness recantations)
- Larrison v. United States, 24 F.2d 82 (7th Cir. 1928) (three‑prong test for new trial based on witness recantation)
- Peirce, 364 N.W.2d 801 (Minn. 1985) (court lacks authority to grant witness immunity absent prosecutorial request)
- Chambers v. State, 831 N.W.2d 311 (Minn. 2013) (concluding Miller is not retroactive on collateral review)