Johnson v. State
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The Supreme Court held that the decision of the United States Supreme Court in Birchfield v. North Dakota, 579 U.S. __ (2016), and this Court’s decisions in State v. Trahan, 886 N.W.2d 216 (Minn. 2016), and State v. Thompson, 886 N.W.2d 224 (Minn. 2016), announced a new rule of constitutional law that applies retroactively to cases on collateral view.
In this consolidated appeal arising from two separate traffic stops, the Supreme Court reviewed the decision of the court of appeals concluding that the Birchfield rule did not apply retroactively to Defendant’s final convictions because the rule was procedural in nature, and that, therefore, the district courts properly denied Defendant’s postconviction petitions. The Supreme Court reversed and remanded to the district court for further proceedings, holding that the Birchfield rule is substantive and applies retroactively to Defendant’s convictions on collateral review.
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