Maurice Lovell Anderson v. State of Minnesota, A16-588

In July 2006 Anderson shot and killed Julian Roland in a crowded bar; two bystanders were also wounded. He claimed self-defense.
Initial charges included second-degree intentional murder and two counts of second-degree assault; four days before trial the complaint was amended to add attempted second-degree murder charges and assault-with-a-weapon.
At Anderson’s request his lawyer declined lesser-included instructions, but the state asked and the district court nevertheless instructed the jury on five lesser-included offenses (felony murder based on assault, two first-degree assaults, two second-degree assaults).
The jury acquitted Anderson of the originally charged counts and convicted him of the five lesser-included offenses; he received consecutive prison terms totaling substantial years. This court affirmed the convictions on direct appeal in 2009; review was denied by the Minnesota Supreme Court.
Anderson filed a postconviction petition in 2015 (raising improper lesser-included instructions, ineffective assistance of trial and appellate counsel, and interests-of-justice), which the district court denied as untimely and Knaffla-barred; Anderson appeals that denial.

Issue	Anderson's Argument	State's Argument	Held
Timeliness of postconviction petition	Petition timely under interests-of-justice or new-evidence exceptions	Petition untimely; no exception applies	Denied as untimely; petition filed >2 years after direct appeal and exceptions not met
Newly discovered evidence exception	Affidavits from eyewitnesses and trial counsel are new and could not have been obtained earlier	Evidence could have been obtained with due diligence after 2009; petition thus time-barred	Exception not met because Anderson failed to show due diligence or why evidence was unavailable earlier
Ineffective assistance (trial & appellate)	Counsel ineffective at trial and on direct appeal; appellate counsel’s failure ripened only after federal denial	Claims arose at trial or on direct appeal; federal habeas outcome irrelevant to timeliness	Claims untimely; cause of action accrued at trial or upon direct appeal, not upon later federal rulings
Supervisory relief / interests of justice review	Court should use supervisory power to reach merits because substantial injustice occurred	Only Minnesota Supreme Court has supervisory authority; appeals court lacks power	Denied—appellate court lacks supervisory authority to grant the relief sought

Matakis v. State, 862 N.W.2d 33 (Minn. 2015) (standard of review for postconviction-denial appeals)
Sanchez v. State, 816 N.W.2d 550 (Minn. 2012) (when a claim "arises" for postconviction timing – knowledge trigger)
Roberts v. State, 856 N.W.2d 287 (Minn. App. 2014) (deadline-exception invocation must itself be timely)
State v. Fellegy, 819 N.W.2d 700 (Minn. App. 2012) (appellate affirmance may be affirmed on any proper ground)
State v. Beecroft, 813 N.W.2d 814 (Minn. 2012) (supervisory authority resides with the supreme court)
State v. Ramey, 721 N.W.2d 294 (Minn. 2006) (discussing supervisory power and appellate limits)
Anderson v. King, 732 F.3d 854 (8th Cir. 2013) (federal habeas denial referenced in procedural history)