Cited by
Opinions in Minnesota that cite Buckingham v. State, 799 N.W.2d 229.
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Michael Arthur Rock, petitioner, Appellant,
Minn. Ct. App. 2025
-05 (Minn. 2013); , 233-34 (Minn. 2011).
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Bruce Ray Fairbanks, petitioner, Appellant,
Minn. Ct. App. 2025
Postconviction petitions are subject to certain procedural requirements including the Knaffla rule, which “provides that when a petition for postconviction relief follows a direct appeal of a conviction, all claims raised in the direct appeal and all claims of which the defendant knew or should have known at the time of the direct appeal are procedurally barred.”
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Roosevelt Bartu, Jr., petitioner, Appellant,
Minn. Ct. App. 2025
(holding that appellant’s postconviction-relief claim asserting a Miranda violation was Knaffla-barred because it turned on “facts that were known or should have been known to him at the time of his direct appeal”).
- A23-1099 Rashad Ramon Ivy v. State of Minnesota Minn. Ct. App. 2024
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A23-1099 Rashad Ramon Ivy v. State of Minnesota
Minn. Ct. App. 2024
Accordingly, when “a petition for postconviction relief follows a direct appeal of a conviction, all claims raised in the direct appeal and all claims of which the defendant knew or should have known at the time of the direct appeal are procedurally barred.” (citing Knaffla, d at 741); see Minn. Stat. § 590.01, subd.
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Charles Earl Strother, petitioner, Appellant,
Minn. Ct. App. 2022
Appellant has not 10 articulated why either exception should apply, “and we have previously declined to apply the exceptions in the absence of such reasons.” (placing burden of proof on petitioner).
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Lance Arnold Kingbird, petitioner, Appellant,
Minn. Ct. App. 2021
Nevertheless, a claim is not Knaffla-barred if (1) “the defendant presents a novel legal issue” or (2) “the interests-of-justice require the court to consider the claim.”
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Anthony Scott David Auginaush, petitioner, Appellant,
Minn. Ct. App. 2021
1 (2020), which states that a petition for postconviction relief filed after the disposition of a direct appeal “may not be based on grounds that could have been raised on direct appeal of the conviction or sentence.” interests of justice require the court to consider the claim.” Buckingham v. State
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John Louis Corrigan, petitioner, Appellant,
Minn. Ct. App. 2021
Buckingham v. State , d 229, 233 (Minn. 2011).
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James Michael Soderbeck, petitioner, Appellant,
Minn. Ct. App. 2021
The Minnesota Supreme Court has held that “when a petition for postconviction relief follows a direct appeal of a conviction, a ll claims raised in the direct appeal and all claims of which the defendant knew or should have known at the time of the direct appeal are procedurally barred.” Davis v. State , (); see also Minn. Stat. § 590.01, subd.
- State of Minnesota, Respondent, Minn. Ct. App. 2021
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Minn. 2020
–32 (Minn. 4 In its order, the district court found that, because Ms. Collier is an unknown person and was not subject to qualification or cross-examination as a witness, the information she provided in her affidavit did not hold evidentiary value at this stage of
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David Laurence Hodges, petitioner, Appellant,
Minn. Ct. App. 2020
rict court noted that “[t]here is no interest[s] of justice exception based on new case law.” “The Knaffla rule provides that when a petition for postconviction relief follows a direct appeal of a conviction, all claims raised in the direct appeal and all claims of which the defendant knew or should have known at the time of the direct appeal are procedurally barred.”
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A19-0676
Minn. Ct. App. 2020
“A claim is not Knaffla-barred, however, if (1) the defendant presents a novel legal issue or (2) the interests of justice require the court to consider the claim.”
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Prince Lashone Holt, petitioner, Appellant,
Minn. Ct. App. 2019
“A claim is not Knaffla-barred, however, if (1) the defendant presents a novel legal issue or (2) the interests of justice require the court to consider the claim.”
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John Louis Corrigan, petitioner, Appellant,
Minn. Ct. App. 2019
(holding that an argument is Knaffla-barred because the petitioner failed to explain “why [the] argument was not available on direct appeal” and “why his failure to raise [the] argument should be excused”); (“A petitioner bear s the burd
- Onyelobi v. State 932 N.W.2d 272 Minn. 2019
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Onyelobi v. State
932 N.W.2d 272
Minn. 2019
See Buckingham v. State , , 232 (Minn. 2011) (holding that the petitioner's arguments were Knaffla barred because we had "expressly considered and rejected identical arguments in [petitioner's] direct appeal"); see also Minn. Stat. § 590.04 , subd.
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A18-1163 A18-1962 A18-1963
Minn. Ct. App. 2019
“A claim is not Knaffla-barred, however, if (1) the defendant presents a novel legal issue or (2) the interests of justice require the court to conside r the claim.”
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Michael David Henderson, petitioner, Appellant,
Minn. Ct. App. 2019
“A claim is not Knaffla-barred, however, if (1) the defendant presents a novel legal issue or (2) the interests of justice require t he court to consider the claim.”
- Crow v. State 923 N.W.2d 2 Minn. 2019
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Crow v. State
923 N.W.2d 2
Minn. 2019
Davis v. State , , 377 (Minn. 2016) (quoting Buckingham v. State , , 231 (Minn. 2011) ).
- State of Minnesota, Respondent, Minn. Ct. App. 2018
- Brown v. State 895 N.W.2d 612 Minn. 2017
- Brown v. State 895 N.W.2d 612 Minn. 2017
- A16-0648 Minn. 2017
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John Patrick Murphy, petitioner, Appellant,
Minn. Ct. App. 2017
8 the defendant knew or should have known at the time of the direct appeal are procedurally barred.” Buckingham v. State
- Jason Donald Matakis v. State of Minnesota Minn. Ct. App. 2017
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Jason Donald Matakis v. State of Minnesota
Minn. Ct. App. 2017
“To be reviewed in the interests of justice, a claim must have merit and be asserted without deliberate or inexcusable delay.” (quotation omitted).
- Gail v. State 888 N.W.2d 474 Minn. 2016
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Gail v. State
888 N.W.2d 474
Minn. 2016
3], we have consistently held that a claim raised on direct appeal will not be considered upon a1 subsequent petition for postconviction relief.” ()); , 232 n.1 (Minn. 2011) (noting that Minn. Stat. § 590.04 , subd.
- 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
- Jerome Emmanuel Davis v. State of Minnesota 880 N.W.2d 373 Minn. 2016
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Jerome Emmanuel Davis v. State of Minnesota
880 N.W.2d 373
Minn. 2016
“The Knaffla rule provides that when a petition for postconviction relief follows a direct appeal of a conviction, all claims raised in the direct appeal and all claims of which the defendant knew or should have known at the time of the direct appeal are procedurally barred.” see also Knaffla, 309 Minn. at 252, d at 741 (holding that, once a direct appeal has been taken, “all matters raised therein, and all claims known but not raised, will not be considered upon a subsequent petition for postco
- David Richard Carlson v. State of Minnesota Minn. Ct. App. 2016
- Jacquet Deon Munn v. State of Minnesota Minn. Ct. App. 2016
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Jacquet Deon Munn v. State of Minnesota
Minn. Ct. App. 2016
“The Knaffla rule provides that when a petition for postconviction relief follows a direct appeal of a conviction, all claims raised in the direct appeal and all claims of which the defendant knew or should have known at the time of the direct appeal are procedurally barred.”
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David Richard Carlson v. State of Minnesota
Minn. Ct. App. 2016
(noting exceptions to the Knaffla bar).
- Laurie Lea Oliveira v. State of Minnesota Minn. Ct. App. 2016
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Laurie Lea Oliveira v. State of Minnesota
Minn. Ct. App. 2016
(citing Knaffla, 309 Minn. at 252, d at 741); see Minn. Stat. § 590.01, subd.
- Robert Marlyn Taylor v. State of Minnesota 874 N.W.2d 429 Minn. 2016
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Robert Marlyn Taylor v. State of Minnesota
874 N.W.2d 429
Minn. 2016
See Riley, d at 168 (applying the statute of limitations); -34 (Minn. 2011) (addressing Knaffla).
- John Mark Hentges v. State of Minnesota Minn. Ct. App. 2015
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John Mark Hentges v. State of Minnesota
Minn. Ct. App. 2015
“The Knaffla rule provides that when a petition for postconviction relief follows a direct appeal of a conviction, all claims raised in the direct appeal and all claims of which the defendant knew or should have known at the time of the direct appeal are procedurally barred.” d 229, 231 (Minn. 2011).
- Edbert Neal Williams v. State of Minnesota 869 N.W.2d 316 Minn. 2015
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Edbert Neal Williams v. State of Minnesota
869 N.W.2d 316
Minn. 2015
-34 (Minn. 2011) (holding that a postconviction petitioner is not entitled to an evidentiary hearing when the “claims are Knaffla-barred”).
- Frank Duane Lussier v. State of Minnesota 853 N.W.2d 149 Minn. 2014
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Frank Duane Lussier v. State of Minnesota
853 N.W.2d 149
Minn. 2014
As a result, Lussier’s claim is “undoubtedly Knaffla-barred because we expressly considered and rejected [an] identical argument[],” d 229, 232 (Minn. 2011), in an appeal from the denial of Lussier’s first postconviction petition.
- Erickson v. State 842 N.W.2d 314 Minn. 2014