Zumberge v. State
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The Supreme Court affirmed the judgment of the district court summarily denying Appellant's petition for postconviction relief, holding that the alleged facts, even when viewed in a light most favorable to Appellant, conclusively showed that he was entitled to no relief.
Appellant was convicted of murder and attempted murder. Appellant later filed his postconviction petition alleging that several reversible errors were committed by the judge, prosecutor, and his counsel during his jury trial. The district court denied the petition without holding an evidentiary hearing and without addressing the ineffective assistance of appellate counsel claim. The Supreme Court affirmed, holding (1) Appellant's claims were procedurally barred by State v. Knaffla, 243 N.W.2d 737 (Minn. 1976); and (2) the failure to address the ineffective assistance of appellate counsel claim did not require a remand because the facts alleged conclusively showed that Appellant was not entitled to relief on his claim.
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