925 N.W.2d 11
Minn.2019Background
- 1970: Officer James Sackett killed after a false 911 call. Constance Trimble-Smith was the caller; Reed later charged with aiding and abetting and conspiracy based on witness statements and possession of a bolt‑action rifle.
- 2006 trial: Key State evidence included Trimble‑Smith’s testimony that Reed scripted the 911 call and John Griffin’s testimony recounting a confession by Reed; jury convicted Reed and sentenced him to life without release.
- Direct appeal (2007): Minnesota Supreme Court affirmed; held accomplice‑corroboration omission was plain error but not prejudicial, rejected Brady/disclosure and self‑representation claims, and denied new‑trial claim based on an affidavit alleging Trimble‑Smith lied.
- Postconviction petitions: Reed filed multiple petitions (2009, 2016, 2017) raising (inter alia) witness recantations (Griffin and Trimble‑Smith), newly discovered evidence/actual innocence, Brady violations, self‑representation and Confrontation Clause claims. The postconviction court summarily denied the 2016 and 2017 petitions; Reed appealed.
- Lower court reasoning: five of Reed’s claims were time‑barred under the 2‑year postconviction statute (Minn. Stat. § 590.01) and Knaffla; the court held Griffin’s alleged recantation—even if true—would not have resulted in a different verdict given other corroborating evidence.
- Supreme Court holding: Affirmed summary denial. Five claims untimely; Griffin recantation legally insufficient to entitle Reed to a new trial and thus no hearing was required. Justice Thissen concurred in part and dissented in part, arguing an evidentiary hearing on Griffin’s recantation should have been granted.
Issues
| Issue | Reed's Argument | State's Argument | Held |
|---|---|---|---|
| Whether Griffin’s alleged recantation warrants a new trial (Larrison factors) | Griffin recanted; affidavits/letters show he lied at trial and testified to secure sentence reduction, so testimony was false and material | Even without Griffin, other testimony (Trimble‑Smith, Foster, Garrett) and evidence (rifle, association with Clark) would allow same verdict; Reed fails second Larrison prong | Denied: recantation, even if true, would not likely have changed the jury’s verdict; legally insufficient to grant new trial or hearing |
| Whether omission of accomplice‑corroboration instruction was prejudicial (plain‑error review) | Error affected substantial rights because Griffin’s testimony was critical; removal of that testimony changes prejudice analysis | Other corroborative evidence affirmed Trimble‑Smith’s testimony and supported guilt; omission not reasonably likely to affect verdict | Affirmed prior conclusion: omission was plain error but did not affect substantial rights; no reversal |
| Timeliness under Minn. Stat. § 590.01 (Knaffla rule) for multiple claims (Trimble‑Smith recantation, self‑rep, Brady, Confrontation, actual innocence) | Many claims rely on newly discovered evidence or later revelations (e.g., Clark’s plea) and thus fall within exceptions | Reed knew or should have known of the underlying facts long before filing; claims are barred by 2‑year statute and Knaffla barring successive/untimely claims | Denied: five claims barred as untimely; newly‑discovered‑evidence exception not satisfied; interests‑of‑justice exception not shown |
| Self‑representation/right to proceed pro se claim | District court failed to ask Reed how he would proceed if counsel discharged; later affidavits show he lacked knowledge of a motion’s contents | Reed raised and litigated this previously; prior counsel knew the motion’s contents; claim is procedurally barred/time‑barred | Denied: claim was previously litigated or known and untimely under statute |
| Brady/disclosure claims (failure to disclose Trimble‑Smith’s 1972 testimony, reward, initial statements) | State failed to disclose exculpatory or impeachment material that would undermine Trimble‑Smith | Reed had Trimble‑Smith’s 2009 affidavit and knew of these matters well before 2016 petition; claims are time‑barred and cumulative | Denied: time‑barred; not newly discovered within statutory period |
| Confrontation Clause/cross‑examination limitation claim | Trial court limited cross‑examination of Griffin or other witnesses, violating confrontation rights | Reed knew of the limitation for years; claim untimely and procedurally barred | Denied: untimely under § 590.01 and Knaffla |
Key Cases Cited
- State v. Reed, 737 N.W.2d 572 (Minn. 2007) (direct‑appeal decision addressing accomplice‑corroboration, self‑representation, and recantation affidavit)
- State v. Knaffla, 243 N.W.2d 737 (Minn. 1976) (rule limiting successive and repetitious postconviction claims)
- Brown v. State, 895 N.W.2d 612 (Minn. 2017) (test for witness‑recantation new‑trial requests)
- Martin v. State, 825 N.W.2d 734 (Minn. 2013) (standard for granting postconviction evidentiary hearings)
- Ferguson v. State, 645 N.W.2d 437 (Minn. 2002) (discussing Larrison factors and recantation)
- Andersen v. State, 913 N.W.2d 417 (Minn. 2018) (postconviction hearing standards and interests‑of‑justice analysis)
- Ortega v. State, 856 N.W.2d 98 (Minn. 2014) (analysis of second Larrison factor when other trial evidence is significant)