Jackson v. StateAnnotate this Case
The Supreme Court affirmed the judgment of the postconviction court summarily denying Appellant's claims for ineffective assistance of trial and appellate counsel without holding an evidentiary hearing, holding that Appellant's claims were barred by the relevant statute of limitations.
Appellant was convicted of first-degree premeditated murder under an aiding-and-abetting theory of liability. The district court imposed a sentence of life without the possibility of release. Appellant later filed his postconviction petition requesting an evidentiary hearing on his claims for ineffective assistance of trial and appellate counsel and mentioning a motion for testing conducted under Minn. Stat. 590.01, subd. 1a. The postconviction court concluded that Appellant's claims were barred by the two-year statute of limitations, Minn. Stat. 590.01, subd. 4. The Supreme Court affirmed, holding (1) Appellant's claims were barred by the two-year statute of limitations; and (2) Appellant's reference to testing did not satisfy the requirements of subdivision 1a.