Riley v. State, 2012 Minn. LEXIS 399

Riley was convicted by a Carver County jury of three counts of first-degree murder and three counts of second-degree murder for the 1995 Watertown farmhouse killings; the district court imposed three consecutive life sentences and this Court affirmed on direct appeal.
Riley filed a 2007 motion for additional fingerprint and forensic testing, abandoned it, then in 2009-2011 filed a second postconviction petition which the court summarily denied without an evidentiary hearing.
Riley renewed claims based on affidavits from White, Goodwin, and Riley alleging confessions by Joseph Papasodora and sought testing under Minn.Stat. § 590.01, subd. 1a and 4(b).
The postconviction court held the 2011 petition time-barred under Minn.Stat. § 590.01, subd. 4(a) and denied the motion for testing under subd. la, and this Court affirmed.
Riley argues the petition should be heard or relief granted under newly discovered evidence (subd. 4(b)(2)) or interests of justice (subd. 4(b)(5)); the court rejected these arguments as a matter of law.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the second postconviction petition was time-barred and not saved by exceptions	Riley claims newly discovered evidence or interests of justice exceptions apply	State argues petition time-barred and exceptions inapplicable	Time-barred; exceptions neither satisfied nor applicable
Whether the affidavits raise newly discovered evidence or require an evidentiary hearing	Evidence is newly discovered and not previously available	Evidence not newly discovered; hearsay and lack of corroboration	Fails to meet newly discovered evidence requirements; hearsay and corroboration deficiencies bars relief
Whether Riley is entitled to postconviction relief under the interests of justice exception	Delay in asserting claim warranted relief	Riley delayed for 16 years without justification; exception not met	Not met; interests of justice exception denied
Whether the postconviction court erred in denying the fingerprint/DNA testing motion under Minn.Stat. § 590.01, subd. la	New testing could exonerate or reveal other perpetrators	Testing sought did not meet statutory criteria because technology was available at trial or not sufficiently changed	Denied; motion did not satisfy subdivision la requirements

State v. Riley, 568 N.W.2d 518 (Minn. 1997), 568 N.W.2d 518 (Minn. 1997) (direct appeal affirmance of convictions)
Riley v. State, 792 N.W.2d 831 (Minn. 2011), 792 N.W.2d 831 (Minn. 2011) (time-bar and postconviction standards affirmed)
State v. Gisege, 582 N.W.2d 229 (Minn. 1998), 582 N.W.2d 229 (Minn. 1998) (DNA testing relief framework in postconviction)
State v. Hawes, 801 N.W.2d 659 (Minn. 2011), 801 N.W.2d 659 (Minn. 2011) (newly discovered evidence standards; credibility)
State v. Hurd, 763 N.W.2d 17 (Minn. 2009), 763 N.W.2d 17 (Minn. 2009) (corroboration requirement for statements against interest)
State ex rel. Roy v. Tahash, 277 Minn. 238, 152 N.W.2d 301 (1967), 277 Minn. 238, 152 N.W.2d 301 (Minn. 1967) (two-step approach to postconviction relief)
Dobbins v. State, 788 N.W.2d 719 (Minn. 2010), 788 N.W.2d 719 (Minn. 2010) (hearsay considerations in postconviction hearings)
State v. Roby, 808 N.W.2d 20 (Minn. 2011), 808 N.W.2d 20 (Minn. 2011) (deceased declarant and hearsay exceptions)
State v. Gassler, 787 N.W.2d 575 (Minn. 2010), 787 N.W.2d 575 (Minn. 2010) (timeliness and exceptions under § 590.01)
Colbert v. State, 811 N.W.2d 103 (Minn. 2012), 811 N.W.2d 103 (Minn. 2012) (Knaffla and postconviction relief principles)