Cited by

See Campbell v. State , (“If a witness has a lready been impeached, further impeachment would be unlikely to have an effect on the outcome of the case.”).

Appellate courts “review the denial of a petition for postconviction relief, including the petitioner’s request for an evidentiary hearing, for an abuse of discretion.”

DECISION Appellate courts “review the denial of a petition for postconviction relief, including the petitioner’s request for an evidentiary hearing, for an abuse of discretion.”

Appellate courts “review the denial of a petition for postconviction relief, including the petitioner’s request for an evidentiary hearing, for an abuse of discretion.”

ANALYSIS “We review the denial of a petition for postconviction relief, including the petitioner’s request for an evidentiary hearing, for an abuse of discretion.”

“We review the denial of a petition for postconviction relief, including the petitioner’s request for an evidentiary hearing, for an abuse of discretion.”

3 Although Larrison was overruled in Mitrione, “Minnesota courts continue to apply the Larrison test in cases involving witness-recantation and false-testimony claims.” n.2 (Minn. 2018).

said he stole about 200 vehicles for 5 Although Larrison was overruled by Mitrione, “Minnesota courts continue to apply the Larrison test in cases involving witness-recantation and false-testimony claims.” n.2 (Minn. 2018).

4 The Larrison test requires that: (1) the court is reasonably well-satisfied that the testimony given by a material witness is false; (2) without that testimony the jury might have reached a different conclusion; and (3) the party seeking a new trial was taken by surprise when the false testim

Three elements must be met to succeed on the claim of a Brady violation: “(1) the evidence must be favorable to the defendant as either exculpatory or impeaching; (2) the evidence must have been suppressed by the prosecution, intentionally or otherwise; and (3) the evidence must be material.”

Campbell v. State , n.2 (Minn. 2018) ; see also Larrison v. United States , 24 F.2d 82, 87- 88 (7th Cir. 1928) (establishing test), overruled by United States v. Mitrione , 357 F.3d 712, 718 (7th Cir. 2004) , vacated on other grounds, 543 U.S. 1097 (2005).

n.2 (Minn. 2018); see Larrison v. United States, 24 F.2d 82, 87-88 (7th Cir. 1928) (establishing test), overruled by United States v. Mitrione, 357 F.3d 712 (7th Cir. 2004), vacated on other grounds, 543 U.S. 1097 (2005).

But “[w]e review legal issues de novo and factual findings for clear error.”

“[H]earsay evidence is 8 [never] sufficient to warrant a ne w trial under the first prong of Larrison.”

Courts have since referred to an alleged or proven violation of this principle as a “Brady violation.” See

See, (noting that if a witness has already been impeached, further impeachment is unlikely to affect the outcome of the case).

(holding that the court need not reach the second and third prongs of the Larrison test because the petitioner failed to satisfy the first prong).

A reasonable probability is one that is sufficient to undermine confidence in the outcome.” (quotations and citations omitted).

Campbell v. State , , 506 (Minn. 2018).

“Three elements must be met to succeed on the claim of a Brady violation: (1) the evidence must be favorable to the defendant as either exculpatory or impeaching; (2) the evidence must have been suppressed by the prosecution, intentionally or otherwise; and (3) the evidence must be material.”

Appellant’s guilty plea resulted in an illegal sentence by purporting to exclude a supervised-release term.

Campbell v. State , , 506 (Minn. 2018).

n. 5 (Minn. 2018) (noting that this co urt declines to address allegations unsupported by legal analysis or citation).

See Campbell v. State , -11 (Minn. 2018) (defining p rejudice prong of Brady in terms of materiality, which requires “a reasonable probability that, had the 2 Rudolph did not claim self-defense.

said she testified falsely, but “hearsay evidence is [never] sufficient to warrant a new t rial under the first prong of Larrison.” Campbell v. State