Michael Wayne v. State of Minnesota, 866 N.W.2d 917

In 1987 Michael Wayne (then Michael Fenney) was convicted of first-degree murder and sentenced to life; conviction was affirmed on direct appeal.
Wayne filed multiple postconviction petitions and a DNA-testing motion over the years; each prior petition was denied and those denials were affirmed on appeal.
In 2014 Wayne filed his seventh postconviction petition asserting: actual innocence, Fourth Amendment search/seizure and recording claims, trial errors (failure to instruct on lesser sexual-offense included offenses, prosecutorial misconduct), and constitutional challenge to limits on appointed counsel; he also alleged ineffective assistance of trial counsel.
The postconviction court denied the petition without an evidentiary hearing as time-barred under Minn. Stat. § 590.01 and procedurally barred under Knaffla; Wayne appealed.
Wayne argued McQuiggin v. Perkins and the "interests of justice" exception to overcome Minn. Stat. § 590.01's deadline; he offered no new evidence of actual innocence.
The Supreme Court of Minnesota affirmed, concluding McQuiggin does not apply to state statutory postconviction time bars and that Wayne failed to show the extraordinary circumstances required to invoke the interests-of-justice exception.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Wayne's 2014 petition is time-barred under Minn. Stat. § 590.01	Wayne: actual-innocence claim and McQuiggin preclude time bar	State: Minnesota postconviction statute controls; petition untimely	Petition is time-barred under § 590.01; affirmed
Whether McQuiggin applies to state postconviction limitations	Wayne: McQuiggin's actual-innocence gateway removes state time limits	State: McQuiggin governs federal habeas only; not applicable	McQuiggin does not apply to § 590.01 petitions
Whether Wayne presented new evidence sufficient to satisfy McQuiggin standard	Wayne: asserts factual innocence based on prior record	State: no new evidence provided to show no reasonable juror would convict	Wayne offered no new evidence; McQuiggin standard not met
Whether the "interests of justice" exception (§ 590.01, subd. 4(b)(5)) saves the petition	Wayne: pro se status, limited education, and alleged miscarriages of justice warrant exception	State: exception is for injustice that caused missing the deadline; prior filings show ability to file timely	Exception not met; court rejects pro se/education argument and denies relief

McQuiggin v. Perkins, 569 U.S. 383 (2013) (actual-innocence gateway can overcome federal habeas statute of limitations)
State v. Fenney, 448 N.W.2d 54 (Minn. 1989) (direct appeal affirming conviction)
State v. Knaffla, 243 N.W.2d 737 (Minn. 1976) (procedural bar doctrine for postconviction claims)
Sanchez v. State, 816 N.W.2d 550 (Minn. 2012) (deadline rules for convictions final before Aug. 1, 2005)
Riley v. State, 819 N.W.2d 162 (Minn. 2012) (summary denial of time-barred postconviction petitions)
Staunton v. State, 842 N.W.2d 3 (Minn. 2014) (postconviction court may summarily deny time-barred petitions)
Erickson v. State, 842 N.W.2d 314 (Minn. 2014) (pro se status and limited education do not alone satisfy interests-of-justice exception)