Campbell v. StateAnnotate this Case
The Supreme Court affirmed the decision of the postconviction court denying Appellant’s petition for postconviction relief without an evidentiary hearing, holding that the postconviction court did not abuse its discretion.
Appellant was found guilty of first-degree premeditated murder committed for the benefit of a gang. Appellant filed a petition for postconviction relief alleging a witness-recantation claim, ineffective assistance of trial counsel, and a Brady violation. The postconviction court denied the petition without holding an evidentiary hearing. The Supreme Court affirmed, holding that the postconviction court did not abuse its discretion when it summarily denied (1) Appellant’s witness-recantation claim where the evidence presented in support of the claim lacked sufficient indicia of trustworthiness; (2) Appellant’s ineffective assistance of counsel claim because the claim was Knaffla-barred; and (3) Appellant’s Brady-violation claim because the record conclusively showed that Appellant was not entitled to relief.