Lyndsey Rae Kidd v. State of Minnesota, A16-78

Background

On Jan. 7, 2011, police observed Lyndsey Rae Kidd at a suspected drug location; she admitted to possessing methamphetamine in her bra and trading 1.75 grams for a CD player. Kidd pleaded guilty to fifth-degree possession (Mar. 10, 2011) and received stayed sentence with probation.
While on probation, Kidd was found with 4.63 grams of methamphetamine hidden on her person during a strip search in custody; she pleaded guilty to third-degree possession (Feb. 17, 2012) and the court later revoked probation.
In July 2014 Kidd filed postconviction petitions raising newly discovered evidence (SPPD crime-lab deficiencies), Brady and due-process claims, manifest injustice, and ineffective assistance of counsel, arguing exceptions to Minn. Stat. § 590.01’s two-year filing limit.
The postconviction court summarily denied relief as untimely; Kidd appealed, arguing the newly-discovered-evidence and interests-of-justice exceptions apply.
The court treated Kidd’s pleas as counseled guilty pleas that waived nonjurisdictional pre-plea defects, analyzed whether she could withdraw pleas for manifest injustice or show ineffective assistance, and compared her arguments to precedent rejecting similar SPPDCL-based claims.

Issues

Issue	Kidd's Argument	State's Argument	Held
Whether SPPDCL testing deficiencies satisfy newly-discovered-evidence exception to §590.01 time bar	Kidd: deficiencies were not discoverable until 2012 and thus fit the exception	State: Kidd had access to lab-based evidence and could have challenged results earlier; deficiencies do not prove innocence	Denied — Kidd failed due-diligence showing and failed to prove innocence by clear and convincing evidence
Whether interests-of-justice exception allows untimely petition	Kidd: petition is non-frivolous and merits review given lab issues and Brady/due-process claims	State: Guilty pleas waived nonjurisdictional claims; any challenge must be via manifest injustice or ineffective-assistance grounds	Denied — guilty pleas waived the asserted pre-plea defects; court need only consider manifest injustice / ineffective-assistance claims
Whether Kidd’s guilty pleas were involuntary, unintelligent, or inaccurate (manifest injustice)	Kidd: plea unknowingly waived right to challenge lab evidence; plea accuracy/voluntariness undermined by later-discovered lab issues	State: Kidd admitted substance and weight at plea hearings, signed plea petitions acknowledging rights and voluntariness	Denied — factual admissions supplied a proper basis; pleas were knowing, voluntary, and intelligent
Whether counsel rendered ineffective assistance by not demanding/reviewing SPPDCL files	Kidd: counsel unreasonably failed to obtain lab files and investigate deficiencies	State: No evidence counsel advised against file requests; discovering SPPDCL issues required special effort beyond customary defense practice; performance presumed reasonable	Denied — Kidd failed to show counsel performance was objectively unreasonable or that she was prejudiced

Key Cases Cited

Roberts v. State, 856 N.W.2d 287 (Minn. App. 2014) (rejecting SPPDCL deficiencies as qualifying newly-discovered evidence and addressing due-diligence and innocence standards)
State v. Ford, 397 N.W.2d 875 (Minn. 1986) (counseled guilty plea waives nonjurisdictional pre-plea defects)
State v. Lothenbach, 296 N.W.2d 854 (Minn. 1980) (standards for withdrawing guilty pleas)
Perkins v. State, 559 N.W.2d 678 (Minn. 1997) (manifest injustice defined by accuracy, voluntariness, and intelligence of plea)
State v. Ecker, 524 N.W.2d 712 (Minn. 1994) (factual-basis requirement for accurate plea)
Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-prong test for ineffective assistance of counsel)
State v. Vang, 847 N.W.2d 248 (Minn. 2014) (presumption that counsel’s performance is reasonable)

Affirmed.