Miller v. State, 2012 Minn. LEXIS 304

Miller pleaded guilty to intentional second-degree murder of Lindorff by an Alford plea on March 11, 2005.
Sentenced on April 11, 2005 to 406 months after district court denied his motion to withdraw the plea.
Miller’s direct appeal was voluntarily dismissed, so the conviction was not reviewed on appeal.
On May 11, 2009, Miller filed a petition for postconviction relief alleging, among other things, lack of a factual basis, ineffective trial counsel, and prosecutorial misconduct.
The postconviction court denied relief as untimely and meritless; the court of appeals affirmed, holding claims untimely because they arose by April 6, 2005.
Miller contends the interests-of-justice exception or constitutional challenges save the petition from time-bar; the Supreme Court ultimately affirms dismissal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Timeliness under § 590.01	Miller argues interests-of-justice tolls apply.	State argues 2-year limit applies to all 4(b) exceptions.	Untimely under 4(c); 2-year limit applies.
Interests-of-justice exception application	Exception should allow timely review of his claims.	Claims arose by April 6, 2005; not timely under 4(c).	Not timely; arising date precedes filing by over 4 years.
Constitutional challenges to time limits	Time limits violate Minnesota Constitution and separation of powers.	Time limits constitutionally applied; previously rejected in Carlton and Sanchez.	Constitutional challenges rejected; limits properly applied.

Sanchez v. State, 816 N.W.2d 550 (Minn.2012) (2-year limit applies to all 4(b) exceptions including interests of justice)
Carlton v. State, 816 N.W.2d 590 (Minn.2012) (constitutional challenges to postconviction time limits rejected)
North Carolina v. Alford, 400 U.S. 25 (U.S. Supreme Court 1970) (Alford plea explained as guilty plea despite asserted innocence)
Goulette v. State, 258 N.W.2d 758 (Minn.1977) (Alford framework adopted in Minnesota)