Cited by

“Generally, there are two types of error: structural error and trial error.”

Knaffla precludes review of “all claims raised in the direct appeal and all claims that were known or should have been known but were not raised in the direct appeal.” see also Minn. Stat. § 590.01, subd.

(stating that “a postconviction court may summarily deny a claim that is untimely under the postconviction statute of limitations”).

A second procedural bar also applies after a litigant makes a direct appeal, prohibiting the litigant from raising (1) issues already raised in a direct appeal, (2) any “claims known but not raised,” or (3) any claims that “should have been known but were not raised in the direct appeal.” State v. Knaffla

4(b), a petition filed outside the statute of limitations may be summarily denied

That procedural bar, also known as the Knaffla rule, “bars consideration of claims that were raised, or could have been raised, in a previous postconviction petition.”

When, as here, a criminal defendant has had a direct appeal, “all claims raised in the direct appeal and all claims that were known or should have been known but were not raised in the direct appeal are procedurally barred.” (emphasis in original).

4(a), or procedurally barred under Knaffla.”

(emphasis omitted) (describing the “reformulated .

6 “A postconviction court need not grant a hearing on a claim if the files and records of the proceeding conclusively establish that the petitioner is not entitled to relief.” (citing Minn. Stat. § 590.04, subd.

A district court “does not abuse its discretion when it summarily denies a petition that is procedurally barred by the Knaffla rule.” ().

“Accordingly, a postconviction court may summarily deny a claim that is untimely under the 2-year statute of limitations.” Rossberg, d at 9 ().

- 26 (Minn. 2015) (citing State v. Knaffla , ).

procedurally barred under Knaffla.” Xiong argues the district court’s denial of his postconviction petition was an abuse of discretion for four reasons, which we discuss in turn.

Because it appears to us that we can “quantitatively assess[]” th e error that Morales asserts “in the context of the other evidence presented in order to de termine whether it was harmless,” (quotation omitted), and be cause Morales presents no argument to the contrary, we decline to apply structural-error review here.

Under the Knaffla rule, “once a direct appeal has been taken, all claims raised in the direct appeal and all claims that were known or sh ould have been known but were not raised in the direct appeal are procedurally barred.” (emphasis omitted).

“Under the interests -of-justice exception to the Knaffla rule, the court may review a claim as fairness requires when the claim has substantive merit and the petitioner did not deliberately and inexcusably fail to raise the issue in the direct appeal or a previous postconviction petition.”

75, 113 S. Ct. 2078 (1993) (constitutionally deficient reas onable-doubt instruction to jury); Waller v. Georgia, 467 U.S. 39, 104 S. Ct. 2210 (1984) (denial of the right to a public 8 A trial error, on the other hand, “may be quantitatively assessed in the context of the other evidence presented in order to dete rmine whether it was harmless beyond a reasonable doubt.” Colbert v. State , (quotation omitted).

7 see also Minn. Stat. § 590.04, subd.

A district court “does not abuse its discretion when it summarily denies a petition that is procedurally barred by the Knaffla rule.” ().

Under the Knaffla rule, “once a direct appeal has been taken, all claims raised in the direct appeal and all claims that were known or should have been known but were not raised in the direct appeal are procedurally barred.” (emphasis omitted).