Tracy Alan Zornes v. State of Minnesota, 880 N.W.2d 363

In Feb. 2010 two victims were beaten, stabbed, and the apartment set on fire; Zornes was arrested weeks later with a pocketknife on his person and tools at a campsite.
Zornes was convicted of two counts of first-degree premeditated murder, first-degree arson, and motor-vehicle theft; convictions and sentences were affirmed on direct appeal.
Zornes filed a postconviction petition raising trial-error claims, multiple ineffective-assistance-of-trial-counsel claims (including failure to exclude the pocketknife), and ineffective-assistance-of-appellate-counsel claims.
The postconviction court denied relief without an evidentiary hearing, treating most trial-error and trial-counsel claims as Knaffla-barred and finding appellate-counsel claims meritless.
The Supreme Court reviewed for abuse of discretion, applying the standard that a hearing is required only if the petition plus files and records do not conclusively show no entitlement to relief and the petitioner alleged facts (not mere argument) that, if proven, would meet Strickland.

Issue	Plaintiff's Argument (Zornes)	Defendant's Argument (State)	Held
1) Procedural bar (Knaffla) for trial errors	Trial errors at trial denied a fair trial and can be raised postconviction	Claims were known or should have been known at direct appeal and are Knaffla-barred	Court: Trial-error claims are procedurally barred; denial without hearing was not abuse of discretion
2) IAC — trial counsel (various on-record errors)	Counsel failed to object/preserve and was ineffective on seven trial-record issues	Issues are record-based and could have been raised on direct appeal; Knaffla applies	Court: These IAC claims are Knaffla-barred
3) IAC — trial counsel (failure to exclude pocketknife)	Autopsy reports (outside trial record) show knife could not have caused some wounds; counsel unreasonably failed to pursue this => hearing needed	Counsel filed a motion to exclude, cross-examined ME, and reasonably chose litigation strategy; record shows performance was reasonable	Court: Even assuming not barred, record conclusively shows counsel was not ineffective; no hearing required
4) IAC — appellate counsel (failure to raise prosecutorial misconduct & slide presentation)	Appellate counsel omitted stronger issues (e.g., comments implying defendant’s silence; inflammatory slides)	Appellate counsel may choose issues; omitted issues were meritless or unsupported by factual allegations	Court: Appellate counsel not ineffective; claims meritless or lacking factual support; denial without hearing affirmed

State v. Knaffla, 243 N.W.2d 737 (procedure that postconviction claims known at direct appeal are barred)
Colbert v. State, 870 N.W.2d 616 (standard of review for postconviction hearing denial)
Matakis v. State, 862 N.W.2d 33 (petition allegations must be more than argumentative assertions)
Schleicher v. State, 718 N.W.2d 440 (files/records can conclusively show entitlement to relief)
Strickland v. Washington, 466 U.S. 668 (two‑prong test for ineffective assistance of counsel)
Wright v. State, 765 N.W.2d 85 (ineffective‑appellate‑counsel claims may be raised postconviction)
State v. DeRosier, 695 N.W.2d 97 (standards for comments on defendant’s silence and reversible error)
Andersen v. State, 830 N.W.2d 1 (strong presumption counsel’s performance is reasonable)