Gilbert vs. State
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In the case before the Supreme Court of Minnesota, the appellant, Larry Jonnell Gilbert, was convicted of possession of a firearm by an ineligible person. Gilbert then sought postconviction relief, alleging that the State's DNA expert gave false testimony at trial. The district court granted Gilbert a new trial without explicitly addressing whether Gilbert's claim was procedurally barred under the rule from State v. Knaffla, which states that all matters raised in a direct appeal and all claims known but not raised, will not be considered upon a subsequent petition for postconviction relief. The state appealed this decision and the court of appeals reversed it.
The Supreme Court of Minnesota held that a district court abuses its discretion by granting a petition for postconviction relief without explicitly determining whether the claim is procedurally barred and offering a sufficient explanation to support a determination that the claim is not procedurally barred. Applying this to the facts of the case, the Supreme Court of Minnesota found that the district court abused its discretion by not explicitly determining whether Gilbert's claim was procedurally barred under Knaffla before granting postconviction relief. Therefore, the court affirmed the decision of the court of appeals, but on different grounds.
Regarding the merits of Gilbert's claim about alleged false expert testimony, the court expressed no opinion, as it determined that Gilbert's postconviction claim was procedurally barred under Knaffla.
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