Prentis Cordell Jackson v. State of Minnesota, 883 N.W.2d 272

Background

In 2006, 17-year-old Prentis Jackson was convicted of first-degree premeditated murder for the fatal shooting of a 15-year-old and sentenced to life without possibility of release (LWOR); conviction was affirmed on direct appeal.
In 2013 Jackson petitioned for postconviction relief claiming (1) an eyewitness, Alfred Lamar, recanted trial testimony and (2) his mandatory LWOR sentence for a juvenile is unconstitutional under Miller v. Alabama.
At the evidentiary hearing Lamar invoked his Fifth Amendment right; Jackson offered Lamar’s written out‑of‑court statements and testimony of an investigator to prove recantation and that police coerced Lamar.
The postconviction court excluded Lamar’s out‑of‑court statements under Minn. R. Evid. 804(b)(3) for lack of corroborating circumstances and denied relief on the conviction claim; it denied Miller relief based on then-existing state precedent that Miller was not retroactive.
After oral argument the U.S. Supreme Court decided Montgomery v. Louisiana, holding Miller retroactive; the Minnesota Supreme Court ordered supplemental briefing and reconsidered sentencing relief.
The court affirmed denial of relief on the recantation (hearsay) claim but held Jackson’s mandatory LWOR violated the Eighth Amendment under Miller and Montgomery and vacated the LWOR sentence.

Issues

Issue	Jackson's Argument	State's Argument	Held
Admissibility of Lamar’s out‑of‑court statements under Minn. R. Evid. 804(b)(3) (statements against penal interest)	Lamar’s written statements and investigator’s testimony corroborate a recantation and show statements were against Lamar’s penal interest and trustworthy	Police interview records and investigators’ testimony show no coercion; corroborating evidence lacking; statements unreliable and tainted by efforts to procure them	Postconviction court did not abuse discretion; statements inadmissible under Rule 804(b)(3); conviction challenge denied
Whether Miller (banning mandatory LWOR for juveniles) applies retroactively	Miller applies retroactively; Jackson is entitled to Miller relief because his sentence became final before Miller	Initially argued (per state precedent) Miller did not apply retroactively; after Montgomery, retroactivity established	Montgomery controls: Miller applies retroactively; prior Minnesota cases (Chambers, Roman Nose) overruled on that point
Appropriate remedy for Miller violation (resentencing hearing vs. as‑applied severance/revival)	A fair Miller hearing is not possible after many years; seek as‑applied severance and revival of the last constitutional statute versions to permit parole/supervised release	Courts retain authority to hold Miller hearings as a procedural remedy; remedy question complex	Because a fair, meaningful Miller hearing was infeasible here, court adopted as‑applied severance and revival of the most recent constitutional statutes (2004 versions) as applied to juveniles whose LWOR sentences were final pre‑Miller; vacated LWOR and remanded for life with possibility of release after 30 years

Key Cases Cited

Miller v. Alabama, 132 S. Ct. 2455 (U.S. 2012) (holding mandatory LWOR for juveniles violates Eighth Amendment)
Montgomery v. Louisiana, 136 S. Ct. 718 (U.S. 2016) (Miller rule applies retroactively)
State v. Ali, 855 N.W.2d 235 (Minn. 2014) (considered remedies after Miller; favored remand for Miller hearing in nonretroactive context)
Fedziuk v. Comm'r of Pub. Safety, 696 N.W.2d 340 (Minn. 2005) (remedy by severing unconstitutional amendment and reviving prior constitutional version)
State v. Chauvin, 723 N.W.2d 20 (Minn. 2006) (resentencing/Chauvin remedy precedent)
State v. Ferguson, 826 N.W.2d 808 (Minn. 2013) (factors for evaluating corroborating circumstances under Rule 804(b)(3))
State v. Hurd, 763 N.W.2d 17 (Minn. 2009) (statement‑against‑interest exception requires corroborating circumstances)