Cited by

Opinions in Minnesota that cite Quick v. State, 757 N.W.2d 278.

34 citing documents.

Milton K. Sanders, Appellant, vs. State of Minnesota, Respondent Minn. 2025
Milton K. Sanders, Appellant, vs. State of Minnesota, Respondent Minn. 2025
There are two exceptions to this rule for an unraised claim: when “an issue is ‘so novel that its legal basis was not reasonably available at the time of the direct appeal’ ” or when “a court decides that hearing the claim is ‘in the interest of justice.’ ” –10 (Minn. 2019) ().
Justin Lee Ironhawk, petitioner, Appellant, Minn. Ct. App. 2024
4(a), and a procedural bar on bringing claims that the individual knew or should have known about at the time of an earlier appeal or postconviction petition, d 205, 210 (Minn. App. 2014) (citing Knaffla, d at 741; ).
Fong Lee, petitioner, Appellant, Minn. Ct. App. 2020
at 741; d 278, 280 (Minn. 2008).
Robert Lee Crum, petitioner, Appellant, Minn. Ct. App. 2020
Knaffla, d at 741; 280 (Minn. 2008).
Chim LoVan, petitioner, Appellant, Minn. Ct. App. 2020
This Knaffla bar includes “claims which appellant should have known but did not raise at the time of an earlier review.”
James Michael Soderbeck, petitioner, Appellant, Minn. Ct. App. 2019
But if the offender has had a direct appeal, “all matters raised therein, and all claims known but not raised, will not be considered upon a subsequent petition for postconviction relief.” State v. Knaffla
Andrew Wayne Clarke, petitioner, Appellant, Minn. Ct. App. 2019
Additionally, “where direct appeal has once been taken, all matters raised therein, and all claims known but not raised, will not be considered upon a subsequent petition for postconviction relief .” State v. Knaffla
Reed v. State 925 N.W.2d 11 Minn. 2019
Reed v. State 925 N.W.2d 11 Minn. 2019
Quick v. State , , 281 (Minn. 2008).
Thomas John Rassmussen, Jr., petitioner, Appellant, Minn. Ct. App. 2019
First, novel issues will be considered if their legal basis “was not reasonably available at the time of the direct appeal.” 4 (Minn. 2008).
Crow v. State 923 N.W.2d 2 Minn. 2019
Crow v. State 923 N.W.2d 2 Minn. 2019
Quick v. State , , 280 (Minn. 2008).
State of Minnesota, Respondent, Minn. Ct. App. 2017
Randy Leeroyal Swaney v. State of Minnesota 882 N.W.2d 207 Minn. 2016
Randy Leeroyal Swaney v. State of Minnesota 882 N.W.2d 207 Minn. 2016
Tracy Alan Zornes v. State of Minnesota 880 N.W.2d 363 Minn. 2016
Jerome Emmanuel Davis v. State of Minnesota 880 N.W.2d 373 Minn. 2016
Tracy Alan Zornes v. State of Minnesota 880 N.W.2d 363 Minn. 2016
3 We have previously recognized two exceptions to the Knaffla rule: “(1) an issue so novel that its legal basis was not reasonably available at the time of the direct appeal, or (2) in the interest of justice—when fairness so requires and the petitioner did not deliberately and inexcusably fail to raise the issue on direct appeal.”
Jerome Emmanuel Davis v. State of Minnesota 880 N.W.2d 373 Minn. 2016
A postconviction court should consider a claim if it is “(1) an issue so novel that its legal basis was not reasonably available at the time of the direct appeal, or (2) in the interest[s] of justice—when fairness so requires and the petitioner did not deliberately and inexcusably fail to raise the issue on 6 direct appeal.”
Daniel Leith Renville v. State of Minnesota Minn. Ct. App. 2016
Daniel Leith Renville v. State of Minnesota Minn. Ct. App. 2016
3 If a “‘direct appeal has once been taken, all matters raised therein, and all claims known but not raised, will not be considered upon a subsequent petition for postconviction relief.’” (quoting State v. Knaffla, 309 Minn. 246, 252, ).
Izell Wright Robinson v. State of Minnesota Minn. Ct. App. 2016
Izell Wright Robinson v. State of Minnesota Minn. Ct. App. 2016
The Knaffla rule “precludes consideration of all claims which appellant should have known but did not raise at the time of an earlier review.”
State of Minnesota v. Vidale Lee Whitson, Vidale Lee Whitson v. State of Minnesota, C5-02-2108 876 N.W.2d 297 Minn. 2016
State of Minnesota v. Vidale Lee Whitson, Vidale Lee Whitson v. State of Minnesota, C5-02-2108 876 N.W.2d 297 Minn. 2016
Lovell Nahmor Oates v. State of Minnesota Minn. Ct. App. 2016
Lovell Nahmor Oates v. State of Minnesota Minn. Ct. App. 2016
State v. Knaffla, 309 Minn. 246, 252
Chaun Dubae Carridine v. State of Minnesota 867 N.W.2d 488 Minn. 2015
Chaun Dubae Carridine v. State of Minnesota 867 N.W.2d 488 Minn. 2015
We have recognized two exceptions to the Knaffla bar: a claim should be considered if it is “(1) an issue so novel that its legal basis was not reasonably available at the time of the direct appeal, or (2) in the interest of justice—when fairness so requires and the petitioner did not deliberately and inexcusably fail to raise the issue on direct appeal.”
Washington v. State 845 N.W.2d 205 Minn. Ct. App. 2014
Washington v. State 845 N.W.2d 205 Minn. Ct. App. 2014
Laine v. State 786 N.W.2d 635 Minn. 2010
Laine v. State 786 N.W.2d 635 Minn. 2010
(holding, based on the four factors listed, that the posteonvietion court did not abuse its discretion in denying Quick’s postconviction petition without an evidentiary hearing).