Sontoya v. State, 829 N.W.2d 602

Sontoya was convicted on May 14, 2009, of first‑degree murder while committing first‑degree criminal sexual conduct, and sentenced to life without possibility of release.
On direct appeal, the conviction was affirmed on September 16, 2010.
On September 16, 2011, Sontoya filed a postconviction petition alleging ineffective assistance of counsel due to a conflict of interest involving counsel’s representation of the victim’s cousin in an unrelated federal narcotics case.
The postconviction court summarily denied relief without an evidentiary hearing.
Sontoya argues the conflict claim should not be barred by Knaffla because he did not know of the conflict until after direct appeal and discovery was delayed.
The court affirmed, holding the conflict claim barred by Knaffla and that any potential conflict would not entitle relief on the merits.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was Sontoya’s postconviction IAC claim barred by Knaffla?	Sontoya did not know of the conflict until after appeal; the claim should be novel/exceptional.	Claim was known or could have been known before direct appeal; Knaffla applies.	Yes; Knaffla bars the claim.
Does the alleged counsel conflict warrant relief under Cuyler if not barred?	Conflict potentially affected counsel’s performance and merits relief.	Mere potential conflict does not entitle relief; must show actual adverse effect.	No relief; conflict insufficient to overcome Knaffla or establish merit.
Was an evidentiary hearing required for the petition?	If facts show improper representation, a hearing is necessary.	Record shows claims were procedurally barred; no hearing required.	No evidentiary hearing required; petition properly denied.

State v. Knaffla, 309 Minn. 246 (1976) (Knaffla bar applies to claims raised on direct appeal or known at that time)
Reed v. State, 793 N.W.2d 725 (Minn. 2010) (review of postconviction petitions; threshold analysis)
Davis v. State, 784 N.W.2d 387 (Minn. 2010) (abuse of discretion standard for postconviction denials)
Sanchez-Diaz v. State, 758 N.W.2d 843 (Minn. 2008) (ineffective assistance claims; must be on record or timely raised)
Torres v. State, 688 N.W.2d 569 (Minn. 2004) (IAC claims that could have been raised on direct appeal are barred (Knaffla))
McKenzie v. State, 754 N.W.2d 366 (Minn. 2008) (hearing not required if petition lacks sufficient facts)
Cuyler v. Sullivan, 446 U.S. 335 (1980) (mere possibility of conflict not enough to overturn conviction)
Cuypers v. State, 711 N.W.2d 100 (Minn. 2006) (actual adverse effect required for IAC claim based on conflict)
Brocks v. State, 587 N.W.2d 37 (Minn. 1998) (evidentiary hearing not necessary if lack of sufficient facts)
Buckingham v. State, 799 N.W.2d 229 (Minn. 2011) (Knaffla and postconviction relief standards)
Walen v. State, 777 N.W.2d 213 (Minn. 2010) (threshold merits inquiry in postconviction review)