Williams vs. State of Minnesota
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Edbert Neal Williams was convicted of first-degree murder and first-degree attempted murder in the death of Genelda Campeau and the attack on her adult granddaughter, S.C. Williams was sentenced to life in prison for murder and received a 180-month consecutive sentence for attempted murder. He appealed, and his convictions were affirmed. In this postconviction proceeding, Williams seeks a new trial or an evidentiary hearing based on new DNA evidence not available at the time of trial. Williams asserts the DNA evidence exonerates him and implicates an alternative perpetrator.
Williams had previously filed multiple postconviction relief petitions, all of which were denied. In 2019, Williams filed a motion seeking forensic testing of evidence from the 1996 crime scene. The district court granted the motion, and the Bureau of Criminal Apprehension (“BCA”) analyzed evidence that it had retained from the crime scene. The BCA released three reports in August 2020, September 2020, and November 2022, and a private lab Williams hired released one report in October 2022. Williams asserts that these reports corroborate his claims that he was not at the scene of the crime when it occurred and that an alternative perpetrator killed Genelda.
The district court summarily denied his petition. The court concluded that Williams’s petition was barred by the 2-year time limit for postconviction relief petitions set out in Minnesota Statutes section 590.01, subdivision 4(a) (2022), and that neither the newly-discovered-evidence exception nor the interests-of-justice exception to the time bar applied.
The Supreme Court of Minnesota affirmed the district court's decision. The court found that the new DNA evidence did not meet the clear and convincing standard for newly discovered evidence and, in fact, some of the additional testing points towards Williams as the perpetrator rather than excludes him. The court also rejected Williams's claim that he is entitled to relief based on the interests-of-justice exception because his mental illness prevented him from timely filing his petition. The court noted that Williams had been sufficiently competent to file his direct appeal from his conviction, postconviction petitions, and appeals from postconviction petitions.
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