Miles v. State
2013 Minn. LEXIS 745
| Minn. | 2013Background
- Miles was convicted of first-degree murder for Tyrone Harrell’s killing and his conviction was upheld on direct appeal (Miles I).
- This appeal arises from Miles’s fourth postconviction petition filed Sept. 2011 seeking relief based on newly discovered evidence, including O.B.’s notarized affidavit and statements.
- O.B. attested that he saw Scott shoot Harrell at a Penn Avenue North party and that he waited 14 years to come forward due to fear of Scott.
- The postconviction court held O.B.’s testimony not credible and denied relief; it also examined D.H. and C.B. testimonies and ruled admissibility and credibility issues affected relief.
- The court applied the Rainer v. State standard for newly discovered evidence after determining the untimeliness did not bar consideration due to § 590.01, subd. 4(b)(2) and proceeded to an evidentiary hearing; it denied relief and Miles timely appealed.
- Miles contends the court erred in applying standards and handling posthearing evidence; the State argues correct standard and credibility determinations foreclose relief.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Rainer governs newly discovered-evidence relief when untimely petition is saved by § 590.01(4)(b)(2). | Miles argues § 590.01(4)(b)(2) governs the merits. | State contends Rainer controls the merits after timely determination under the § 4(b) exception. | Rainer applies to merits after time-bar exception. |
| Whether O.B.’s testimony satisfies the third prong of the Rainer test (credibility). | Miles asserts O.B. is credible and should support relief. | State contends O.B. credibility is for the postconviction court’s finder-of-fact. | O.B. not credible; lack of credibility defeats entitlement to relief. |
| Whether D.H.’s testimony would likely yield an acquittal or more favorable outcome. | Miles argues D.H. supports new trial relief. | State contends D.H. is largely cumulative and non-probative. | D.H.’s testimony would not likely produce acquittal or more favorable result. |
| Whether C.B.’s statement against interest was admissible and material for relief. | Miles asserts C.B.’s statement supports new-trial relief. | State argues C.B.’s statement is inadmissible hearsay or only impeachment and not material. | C.B.’s statement was not admissible substantive evidence; impeachment-only testimony cannot satisfy Rainer prongs. |
| Whether post-hearing evidence and interest-of-justice claim justify relief. | Miles seeks relief in the interests of justice. | State argues no merit given lack of substantial new evidence. | No relief in interests of justice; standard not met. |
Key Cases Cited
- Rainer v. State, 566 N.W.2d 692 (Minn. 1997) (establishes four-prong test for newly discovered evidence; burden on petitioner)
- Hurd v. State, 763 N.W.2d 17 (Minn. 2009) (discusses credibility and weight when evaluating new evidence)
- Williams v. State, 692 N.W.2d 893 (Minn. 2005) (distinguishes standard of proof for postconviction relief and § 4(b) exceptions)
- Fort v. State, 768 N.W.2d 335 (Minn. 2009) (affirming deference to credibility findings and evidentiary rulings)
- Pippitt v. State, 737 N.W.2d 221 (Minn. 2007) (new evidence must be material beyond mere impeachment)
- Gassier v. State, 787 N.W.2d 575 (Minn. 2010) (recognizes limited scope of new-evidence review in postconviction)
- Dobbins v. State, — N.W.2d — (Minn. 2013) (discusses hearsay and admissibility issues in postconviction)