Wayne v. State, 832 N.W.2d 831

Wayne was convicted of the 1986 murder of Mona Armendariz and sentenced to life in prison; direct appeal and subsequent postconviction appeals were affirmed.
Armendariz’s death involved beating, stabbing, throat slitting, and a curling iron inserted into the vagina; the trial record is summarized in Fenney.
On February 14, 2012, Wayne filed a motion captioned as DNA analysis under Minn. Stat. § 590.01, subd. la, seeking DNA testing of Armendariz’s underwear.
The postconviction court treated the motion as a fifth petition and held it barred under State v. Knaffla and Minn. Stat. § 590.01, subd. 4(c).
The court concluded Wayne’s motion failed to meet § 590.01, subd. la requirements (identity, chain of custody, and material relevance).
Even if treated as a postconviction petition, the claim was time-barred under § 590.01, subd. 4(a) and 4(c) because accrual occurred in 1998 and the motion was filed in 2012.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the motion for DNA testing is timely under § 590.01, subd. 4(a)/(4c).	Wayne argues the motion is timely as a DNA testing request.	State contends the claim is time-barred under 4(a) and 4(c).	Timeliness barred under subdivision 4(a) and 4(c).
Whether Armendariz’s underwear has a sufficient chain of custody for testing under § 590.01, subd. la(b).	Wayne asserts testing could be relevant to innocence.	State notes lack of demonstrated custody and even availability of the underwear.	Chain of custody not established; testing not lawful under la(b).
Whether DNA testing would be materially relevant to Wayne's actual innocence under § 590.01, subd. la(c)(2).	Testing would show no sexual assault by Wayne and suggest other relationships.	Evidence at trial focused on curling iron; relevance of underwear testing to identity is unclear.	Not shown to be materially relevant to actual innocence under la(c)(2).

Fenney v. State, 448 N.W.2d 54 (Minn. 1989) (summarizes underlying facts of Armendariz case)
Wayne v. State (Wayne III), 601 N.W.2d 440 (Minn. 1999) (discusses Wayne's knowledge of DNA testing and related evidence)
Wayne v. State (Wayne IV), 747 N.W.2d 564 (Minn. 2008) (affirmed denial of prior postconviction relief petitions)
Sanchez v. State, 816 N.W.2d 550 (Minn. 2012) (establishes accrual timing for subsection 4(c) and interpretation of time-bar)
State v. Knaffla, 309 Minn. 246, 243 N.W.2d 737 (Minn. 1976) (Knaffla doctrine—bar for failure to raise issues on direct appeal)