Cited by
Opinions in Minnesota that cite Torres v. State, 688 N.W.2d 569.
- Edbert Neal Williams v. State of Minnesota 869 N.W.2d 316 Minn. 2015
- Chaun Dubae Carridine v. State of Minnesota 867 N.W.2d 488 Minn. 2015
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Chaun Dubae Carridine v. State of Minnesota
867 N.W.2d 488
Minn. 2015
(noting that a claim of ineffective assistance of trial counsel that can be decided on the trial court record must be raised on direct appeal or it is procedurally barred).
- State of Minnesota v. Jyron Mendale Young Minn. Ct. App. 2015
- State of Minnesota v. Jyron Mendale Young Minn. Ct. App. 2015
- Nissalke v. State 861 N.W.2d 88 Minn. 2015
- Nissalke v. State 861 N.W.2d 88 Minn. 2015
- Steven White v. State of Minnesota Minn. Ct. App. 2014
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Steven White v. State of Minnesota
Minn. Ct. App. 2014
This court “will find an implied concession only where a reasonable person viewing the totality of the circumstances would conclude that counsel conceded the defendant[’]s guilt.” (quotations omitted).
- Hooper v. State 838 N.W.2d 775 Minn. 2013
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Hooper v. State
838 N.W.2d 775
Minn. 2013
(stating that the Knaffla rule is “intended to foster” finality and efficiency); (explaining that the Knaffla rule “preserves the goals of finality and efficiency where appropriate and overrides them only where necessary in the interests of justice”).
- Torres v. State 837 N.W.2d 487 Minn. 2013
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Torres v. State
837 N.W.2d 487
Minn. 2013
We affirmed Torres’s conviction on direct appeal, and we subsequently affirmed the summary denial of his first petition for postconviction relief
- Sontoya v. State 829 N.W.2d 602 Minn. 2013
- Sontoya v. State 829 N.W.2d 602 Minn. 2013
- Andersen v. State 830 N.W.2d 1 Minn. 2013
- Andersen v. State 830 N.W.2d 1 Minn. 2013
- State v. Hokanson 821 N.W.2d 340 Minn. 2012
- State v. Hokanson 821 N.W.2d 340 Minn. 2012
- State v. Prtine 784 N.W.2d 303 Minn. 2010
- State v. Prtine 784 N.W.2d 303 Minn. 2010
- State v. McCurry 770 N.W.2d 553 Minn. Ct. App. 2009
- State v. McCurry 770 N.W.2d 553 Minn. Ct. App. 2009
- Barnes v. State 768 N.W.2d 359 Minn. 2009
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Barnes v. State
768 N.W.2d 359
Minn. 2009
*364 Under Knaffla a postconvietion claim is not barred if: (1) “the claim ‘is so novel that the legal basis was not available on direct appeal/ ” and (2) “the petitioner did not ‘deliberately and inexcusably’ ” fail to raise the claim on direct appeal and “ ‘fairness requires its consideration.’ ” ().
- Sanchez-Diaz v. State 758 N.W.2d 843 Minn. 2008
- Sanchez-Diaz v. State 758 N.W.2d 843 Minn. 2008
- Arredondo v. State 754 N.W.2d 566 Minn. 2008
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Arredondo v. State
754 N.W.2d 566
Minn. 2008
Despite the general Knaffla bar, " ‘a claim of ineffective assistance of trial counsel that cannot be decided on the district court record because it requires additional evidence need not be brought on direct appeal and may be brought in a postconviction petition.’ ” (), , 265 n. 5 (Minn.2008).
- McKenzie v. State 754 N.W.2d 366 Minn. 2008
- McKenzie v. State 754 N.W.2d 366 Minn. 2008
- Fields v. State 733 N.W.2d 465 Minn. 2007
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Fields v. State
733 N.W.2d 465
Minn. 2007
The post-conviction court concluded that Fields’ which reaffirmed our rule in State v. Knaffla, 309 Minn. 246
- State v. Jackson 726 N.W.2d 454 Minn. 2007
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State v. Jackson
726 N.W.2d 454
Minn. 2007
Finally, “a claim of ineffective assistance of trial counsel that cannot be decided on the district court record because it requires additional evidence need not be brought on direct appeal and may be brought in a postconviction petition.” (indicating that, when the existing record is insufficient to evaluate counsel’s decisions, a claim of ineffective assistance is properly raised in a postconviction proceeding).
- Erickson v. State 725 N.W.2d 532 Minn. 2007
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Erickson v. State
725 N.W.2d 532
Minn. 2007
The Knaffla rule bars postcon-viction claims of ineffective assistance of trial counsel after direct appeal except when the merits of the claim “cannot be *536 determined from the district court record and requires additional evidence, such as that involving attorney-client communications.”
- Spears v. State 725 N.W.2d 696 Minn. 2006
- Townsend v. State 723 N.W.2d 14 Minn. 2006
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Townsend v. State
723 N.W.2d 14
Minn. 2006
(discussing finality and efficiency as reasons for the Knaffla rule).
- Schleicher v. State 718 N.W.2d 440 Minn. 2006
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Schleicher v. State
718 N.W.2d 440
Minn. 2006
“Under the second exception, we have held that a claim of ineffective assistance of trial counsel is not barred by Knaffla if it cannot be determined from the district court record and requires additional evidence, such as that involving attorney-client communications.” cert.
- State v. Barnes 713 N.W.2d 325 Minn. 2006
- Criticized State v. Barnes 713 N.W.2d 325 Minn. 2006
- White v. State 711 N.W.2d 106 Minn. 2006
- White v. State 711 N.W.2d 106 Minn. 2006
- State v. Martin 695 N.W.2d 578 Minn. 2005
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State v. Martin
695 N.W.2d 578
Minn. 2005
However, “a claim of ineffective assistance of trial counsel that cannot be decided on the district court record because it requires additional evidence need not be brought on direct appeal and may be brought in a postcon-viction petition.”
- Carney v. State 692 N.W.2d 888 Minn. 2005
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Carney v. State
692 N.W.2d 888
Minn. 2005
second Knaffla exception, a claim of ineffective assistance of trial counsel known but not raised at the time of direct appeal may be brought in a postcon-viction petition if the claim cannot be “evaluated by an appellate court on direct appeal based on the briefs and trial court transcript, without any additional factfind-ing.” (“A claim of ineffective assistance of trial counsel that can be decided on the basis of the trial court record must be brought on direct appeal and is procedurally barr