Cited by

see Andersen, d at 10 (stating that “[t]he extent of trial counsel’s investigation is considered part of trial strategy”); (stating that counsel’s decision whether to cross-examine a witness constituted trial strategy); (stating that defense counsel’s decision about what testimony to elicit from a witness on cross-examination constituted a strategic decision).

Appellate courts “generally do not review ineffective assistance of counsel claims based on trial strategy.” Francis v. State, 21

Leake, d at 536 ; (noting that whether to call an expert witness and whether to cross-examine on a certain topic were matters of trial strategy); (holding that counsel’s decision to pursue certain evidence and not other evidence fell within the realm of defense stra

(concluding that whether to cross- examine the state’s expert witnesses constituted trial strategy).

(stating that self-represented party who appears pro se “is held to the standard of an attorney in presenting his appeal”).

Although criminal defendants enjoy the right to counsel at “critical stages of the proceedings,” (quotation omitted), the right to counsel extends only “for one review of a criminal conviction, whether by direct appeal or a first review by postconviction proceeding,” (quotations omitted).

A party that appears pro se “is held to the standard of an attorney in presenting his appeal.”

A pro se party “is held to the standard of an attorney in presenting [an] appeal.” (stating that generally, a court will not modify ordinary rules and procedures because a pro se party lacks the skills and knowledge of an attorney).

denied, 142 S. Ct. 819 (2022); State v. Davis , n.10 (Minn. 2012) (noting that “decisions about which witnesses to interview are typically matters of trial strategy that we will not review”); (noting that whether to cross-examine the state’s expert witness and failure to call alibi witnesses were matters of trial strategy that could not constitute ineffective assistance of counsel); (noting that whether to cross -examine witness was a

(stating appellate courts generally do not review issues of trial strategy and declining to review, in part, the depth of counsel’s investigation into alternative suspects); (concluding in part that whether to cross-examine an expert witness was trial strategy); (“Decisions about which witnesses to call at trial and what information to present to the jury are questions of trial strategy that lie within the disc

See, n.10 (Minn. 2012) (stating decisions about which witnesses to interview are usually matters of trial strategy that appellate courts do not review); (stating whether to cross-examine an expert witness is an issue of trial strategy).

(stating appellant failed to show counsel’s performance fell below an objective standard of reasonableness for failing to call expert witness).

(“Decisions about which witnesses to call at trial and what information to present to the jury are questions of trial 9 strategy that lie within the discretion of trial counsel.”).

See Francis v. State , (declining to consider whether to cross -examine the state’s expert witnesses constitutes erroneous conduct because it relates to trial strategy).

(A party that appears pro se “is held to the standard of an attorney in presenting his appeal.”).

1 (2018); see also Francis v. State , d 892, 896 (Minn. 2010) (recognizing that an evidentiary hearing is unnecessary “if the petitioner fails to allege facts that are suffici ent to entitle him to the relief requested”).

cf. United States v. Orr, 636 F.3d 944, 952 (8th Cir. 2011) (reviewing cross-examination only when it appears counsel utterly failed to “subject the prosecution’s case to .

Se lf-represented litigants “are generally held to the same standards as attorneys and must comply with court rules.” Fitzgerald v. Fitzgerald , (Mi nn.

“Although some accommodations may be made for pro se litigants, this court has repeatedly emphasized that pro se litigants are generally held to the same standards as attorneys and must comply with court rules.” (providing that a party that appears pro se “is held to the standard of an attorney in presenting his appeal”).

See, e.g. , State v. Mosley , , 795 (Minn. 2014) (discussing CSLI evidence but not examining whether it was admissible); Francis v. State , , 895 (Minn. 2010) (same); State v. Tran , , 543 (Minn. 2006) (same).

d 892, 896 (Minn. 2010) (-73 (Minn. 1988)).

Because a defendant bears the burden of advancing reasons to support withdrawal, Raleigh, d at 97, and because pro se litigants are generally held to the same standards as attorneys and must comp ly with all rules of procedure, these general statements fail to meet the requirements for a plea-withdrawal motion.

(concluding that whether 9 to cross-examine the state’s expert witnesses constitutes trial strategy); State v. Pearson

(concluding that petitioner had not shown prejudice because the desired testimony would not have refuted the substantial evidence against him).

Counsel’s decisions not to request a Frye-Mack hearing and not to call the expert at trial fall squarely within “tactical decisions properly left to the discretion of trial counsel.” 8 See Nissalke, d at 111 (quotation omitted) (holding that decision not to file pretrial motion regarding evidence is trial strategy); (holding that decision whether to call expert witness is trial strategy).