Wallace v. State
2012 Minn. LEXIS 495
Minn.2012Background
- Wallace was convicted after a jury trial of first-degree felony murder, attempted second-degree criminal sexual conduct, and second-degree assault; direct appeal affirmed in 1997.
- Wallace filed a first postconviction petition in 2002, which was denied; an appeal was dismissed for inactivity.
- Wallace filed a motion to correct sentence and other relief in 2005, which was denied.
- On April 20, 2011, Wallace filed a second postconviction petition, which the court denied as untimely under Minn. Stat. § 590.01, subd. 4 (2010).
- The issue is whether time-bar exceptions or the interests-of-justice provision allow review of his claims; the court concluded all claims were frivolous and unnecessary to address merits.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the time bar applies to Wallace’s second petition | Wallace invoked interests-of-justice (4(b)(5)) | Wallace’s petition is time-barred and lacks a valid 4(b) exception | Time-bar applies; petition is untimely and not saved by 4(b) exceptions |
| Whether Wallace properly invoked the interests-of-justice exception | Petition urged relief in the interests of justice | No explicit 4(b)(5) basis; arguments fail | Independently invoked but fails on not-frivolous requirement |
| Whether Wallace’s claims were frivolous | Claims were substantial; potential errors could exist | Claims lack any good-faith basis in law or fact | All claims frivolous under Minn. Stat. § 590.01, subd. 4(b)(5) |
| Whether Knaffla precludes review | Challenged application of Knaffla | Court need not address due to timeliness ruling | Knaffla not reached; time bar dispositive |
| Whether the two-year time-bar constitutional issue is resolved | Time bar unconstitutional | Carlton v. State supports constitutionality | Time bar upheld as constitutional (Carlton governs) |
Key Cases Cited
- State v. Skipintheday, 717 N.W.2d 423 (Minn.2006) (multiple-victim sentencing allowed when not unduly exaggerating criminality)
- Knaffla, 309 Minn. 246, 243 N.W.2d 737 (Minn.1976) (bar to claims not raised on direct appeal or in prior petitions)
- Rickert v. State, 795 N.W.2d 236 (Minn.2011) (liberally construed petitions invoke interests-of-justice exception)
- Neitzke v. Williams, 490 U.S. 319 (U.S.1989) (definition of frivolous as lacking arguable basis in law or fact)
- Hodges, 332 Ill.Dec. 318, 912 N.E.2d 1204 (Ill.2009) (definition of frivolous postconviction claims (procedural defects))