Phillip Anthony Roberts v. State of Minnesota, 2014 Minn. App. LEXIS 100

Roberts pleaded guilty in 2005 to second-degree sale of a controlled substance (cocaine) after a traffic stop; he did not appeal his 36-month sentence.
The St. Paul crime lab analyzed the recovered rocks; 21 were tested, weighed 4.16 grams total, and tested positive for cocaine.
In 2012–2013, revelations and audits disclosed procedural and training deficiencies at the crime lab; Roberts learned of those problems years after his plea.
In November 2013 (nearly eight years after conviction), Roberts filed a postconviction petition seeking to withdraw his plea based on the crime-lab deficiencies and alleged ineffective assistance for failure to obtain the lab file.
The postconviction court summarily denied the petition as time-barred under Minn. Stat. § 590.01, subd. 4(a); Roberts appealed claiming two exceptions to the time bar applied.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the newly-discovered-evidence exception allows review of Roberts’s untimely plea-withdrawal petition	Roberts: lab audits and the Dakota County matter constitute newly discovered evidence that could not have been found earlier and undermine the reliability of the drug test	State: Roberts knew the lab results, had discovery rights and means to challenge the tests earlier, and the new evidence does not clearly and convincingly establish actual innocence	Held: Exception does not apply — Roberts failed to show the evidence couldn’t have been discovered with due diligence and did not prove actual innocence by clear and convincing evidence (Riley standard)
Whether the interests-of-justice exception applies to permit review despite untimeliness	Roberts: post-plea revelations about lab practices make it fair to hear his claim now	State: Roberts (not the State) is at fault for failing to investigate pre-plea; no fundamental unfairness or judicial-integrity issue requiring extraordinary relief	Held: Exception does not apply — petition lacks the exceptional circumstances required; Roberts was at fault and no fundamental unfairness was shown

Goeb v. Tharaldson, 615 N.W.2d 800 (Minn. 2000) (proponent of scientific tests must establish foundational reliability)
Olhausen v. State, 681 N.W.2d 21 (Minn. 2004) (identity and weight of controlled substances may be proven by nonscientific evidence)
Riley v. State, 819 N.W.2d 162 (Minn. 2012) (elements and clear-and-convincing standard for newly discovered evidence exception)
Scott v. State, 788 N.W.2d 497 (Minn. 2010) (burden on petitioner to present clear and convincing evidence of innocence)
Shorter v. State, 511 N.W.2d 743 (Minn. 1994) (supervisory-relief example where unusual facts rendered plea suspect)
Gassler v. State, 787 N.W.2d 575 (Minn. 2010) (factors for applying interests-of-justice exception)
Rickert v. State, 795 N.W.2d 236 (Minn. 2011) (consideration of party fault in interests-of-justice analysis)