Lincoln Lamar Caldwell v. State of Minnesota, 853 N.W.2d 766

Background

Caldwell was convicted of first-degree premeditated murder for the benefit of a gang and sentenced to life without release.
Caldwell filed a third postconviction petition alleging that three witnesses—Brooks, Carnell, and S.T.—recanted or testified falsely at trial; he submitted affidavits and investigator-transcribed statements, plus a handwritten note.
The postconviction court denied an evidentiary hearing, concluding the petition failed to show trustworthy recantations and legally sufficient grounds.
The question on appeal was whether the postconviction court abused its discretion by denying an evidentiary hearing under Minnesota’s postconviction procedure and the Larrison standard for false testimony.
The majority remanded for an evidentiary hearing, finding the recantations carried sufficient indicia of trustworthiness and that, if proven, they could affect the verdict; the dissent disagreed, arguing the evidence did not establish a prima facie case for a hearing and that the proper standard was not met.
Key facts include Brooks’s and Carnell’s recantations regarding either the gun transfer or other key trial facts, S.T.’s denial of posttrial testimony, and the court’s treatment of a handwritten note as lacking trustworthiness.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Caldwell is entitled to an evidentiary hearing on false-witness claims under Larrison	Caldwell asserts recantations from Brooks, Carnell, and S.T. are trustworthy and would likely change the verdict	The postconviction court found insufficient indicia of trustworthiness and denied a hearing	Yes; the court abused discretion and remanded for an evidentiary hearing
Whether the first prong of Larrison is satisfied by the alleged recantations	Alleged recantations provide substantial contradictions to trial testimony	Inability to recall or partial contradictions do not by themselves prove false testimony	Yes; the allegations, if true, may show false testimony by material witnesses
Whether the second prong of Larrison shows the verdict could differ absent false testimony	Without the false testimony, the jury might have reached a different conclusion about Caldwell’s guilt as an accomplice	Other independent evidence would sustain the verdict regardless of recantations	Yes; the alleged false testimony could have affected the verdict, requiring a hearing
Whether the third prong of Larrison (surprise) is satisfied	Caldwell was present; there was a potential surprise element in the recantations	Not a prerequisite to granting a hearing under this standard in all cases	Not decisive to deny hearing; the court should consider credibility in light of the hearing
Whether the postconviction court properly applied Pippitt and related precedents in ruling on the petition	Pippitt supports treating an inability to recall as insufficient only when properly confronted with the recantation context	Pippitt controls that inability-to-remember alone is not a recantation	Remand guided by correct application of Larrison and related precedents.

Key Cases Cited

State v. Caldwell, 322 N.W.2d 574 (Minn. 1982) (Larrison standard applied to false testimony claims)
Pippitt v. State, 737 N.W.2d 221 (Minn. 2007) (recantation context and Larrison limitations)
Opsahl v. State, 677 N.W.2d 414 (Minn. 2004) (recantation credibility and evidentiary hearing scope)
Dobbins v. State, 788 N.W.2d 719 (Minn. 2010) (contextual recantation analysis supports hearing when credible risk exists)
Ferguson v. State, 645 N.W.2d 437 (Minn. 2002) (recantation standards and evidence requirements)
Ferguson v. State, 779 N.W.2d 555 (Minn. 2010) (Ferguson II; indicia of trustworthiness and hearing standards)
Martin v. State, 825 N.W.2d 734 (Minn. 2013) (standards for evidentiary hearings in postconviction claims)
Hooper v. State, 680 N.W.2d 89 (Minn. 2004) (evidence standards for credibility and impact)
Riley v. State, 819 N.W.2d 162 (Minn. 2012) (abuse-of-discretion review for postconviction hearings)