Miles v. State
2011 Minn. LEXIS 461
| Minn. | 2011Background
- Miles convicted of first-degree murder of Tyrone Harrell in 1997; direct appeal affirmed in 1998.
- Miles sought postconviction relief many years later (2010) asserting newly discovered evidence via an unsworn interview with O.B.
- Postconviction court denied as time-barred under Minn. Stat. § 590.01, subd. 4, with no relief under the 4(b)(2) exception.
- Court of Appeals reviews de novo; affirmance on time-bar grounds but allows filing of a new petition.
- O.B. statements claim Miles was at a barbecue with Scott, who allegedly shot Harrell and framed Miles; statements not notarized.
- Court considers whether the newly discovered evidence exception requires actual innocence showing or merely a pleading allegation of evidence that could prove innocence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the petition was time-barred under § 590.01, 4(a). | Miles. | State. | Petition timely under exceptions; but affirmed considering other factors (see other issues). |
| Whether O.B.'s statement qualifies as newly discovered evidence under § 590.01, 4(b)(2). | O.B. statement alleges Miles's innocence; not previously discoverable. | Statement not reliably discoverable; not proven innocent by clear and convincing standard. | Court applies newly discovered evidence standard and concludes not conclusively innocent but allows potential renewed petition with better evidence. |
| Whether the evidence would prove innocence by clear and convincing standard. | O.B. would establish Miles's innocence. | O.B.’s recantation lacks reliability; not sworn. | Court acknowledges wrong test applied but ultimately denies hearing due to reliability concerns; not prejudice to future petitions. |
| Whether the court erred in denying relief without a hearing. | O.B. statement could warrant a hearing. | Recantation not sufficiently reliable without oath. | Affirmed denial without prejudice to a new petition if more reliable evidence emerges. |
Key Cases Cited
- Roby v. State, 787 N.W.2d 186 (Minn. 2010) (liberal pleading approach to invoke 4(b) exceptions; not necessary to cite subdivision explicitly)
- Gassier v. State, 787 N.W.2d 575 (Minn. 2010) (newly discovered evidence must show innocence by clear and convincing standard to merit relief)
- Scott v. State, 788 N.W.2d 497 (Minn. 2010) (similar to Gassier; evidence may not prove innocence, but can affect eligibility for relief)
- Ferguson v. State, 742 N.W.2d 651 (Minn. 2007) (recantations require sworn statements for hearings; reliability factor in postconviction relief)
- Opsahl v. State, 677 N.W.2d 414 (Minn. 2004) (recantation considerations in pre-hearing analysis)
- Pierson v. State, 687 N.W.2d 571 (Minn. 2002) (evidence of witness togetherness affecting credibility)