Knaffla rule in Minnesota

2025This principle is often referred to as the Knaffla rule because it is rooted in our decision in State v. Knaffla, 243 N.W.2d 737, 741 (Minn. 1976).

2025This principle is often referred to as the Knaffla rule because it is rooted in our decision in State v. Knaffla, 243 N.W.2d 737, 741 (Minn. 1976).

2017“The Knaffla rule provides that when a petition for postconviction relief follows a direct 10 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.” Hooper v. State, 838 N.W.2d 775, 787 (Minn. 2013) (quotation omitted).

2017“The Knaffla rule provides that when a petition for postconviction relief follows a direct 10 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.” Hooper v. State, 838 N.W.2d 775, 787 (Minn. 2013) (quotation omitted).

2016The Knaffla rule provides that “[o]nce a direct appeal has been taken, all claims that were raised in the direct appeal and all claims that were known or should have been known but were not raised will not be considered upon a subsequent petition for postconviction relief.” White v. State, 711 N.W.2d 106, 109 (Minn.2006) (citing Knaffla, 309 Minn. at 252 , 243 N.W.2d at 741 ).

2016The Knaffla rule provides that “[o]nce a direct appeal has been taken, all claims that were raised in the direct appeal and all claims that were known or should have been known but were not raised will not be considered upon a subsequent petition for postconviction relief.” White v. State, 711 N.W.2d 106, 109 (Minn.2006) (citing Knaffla, 309 Minn. at 252 , 243 N.W.2d at 741 ).

2025That 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.” Colbert v. State, 870 N.W.2d 616, 626 (Minn. 2015).

2025That 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.” Colbert v. State, 870 N.W.2d 616, 626 (Minn. 2015).

2025“Claims of ineffective assistance of appellate counsel . . . are not barred by the Knaffla rule in a first postconviction appeal because they could not have been brought at any earlier time.” Leake v. State, 737 N.W.2d 531, 536 (Minn. 2007).

2025“Claims of ineffective assistance of appellate counsel . . . are not barred by the Knaffla rule in a first postconviction appeal because they could not have been brought at any earlier time.” Leake v. State, 737 N.W.2d 531, 536 (Minn. 2007).

2017Under 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.” Id. at 626 (emphasis omitted) (citing Black v. State, 560 N.W.2d 83, 85 (Minn. 1997)), A claim of ineffective assistance of trial counsel that cannot be decided on the district court record because it requires additional evidence, however, need not be brought on direct appeal and may be brought in a posteonviction petition.

2017Under 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.” Id. at 626 (emphasis omitted) (citing Black v. State, 560 N.W.2d 83, 85 (Minn. 1997)), A claim of ineffective assistance of trial counsel that cannot be decided on the district court record because it requires additional evidence, however, need not be brought on direct appeal and may be brought in a posteonviction petition.

2017The Knaffla rule is intended to preserve “the goals of finality and efficiency where appropriate and overrides them only where necessary in the interests of justice.” Torres v. State, 688 N.W.2d 569, 572 (Minn. 2004).

2017The Knaffla rule is intended to preserve “the goals of finality and efficiency where appropriate and overrides them only where necessary in the interests of justice.” Torres v. State, 688 N.W.2d 569, 572 (Minn. 2004).

2015Roby v. State, 531 N.W.2d 482, 484 (Minn.1995); Case v. State, 364 N.W.2d 797, 801 (Minn.1985) (Wahl, J., concurring specially).

2009Roby v. State, 531 N.W.2d 482, 484 (Minn.1995).

2018Moreover, we have repeatedly applied the Knaffla rule "in postconviction proceedings raising constitutional issues of criminal procedure." Lynch v. State , 749 N.W.2d 318 , 321 (Minn. 2008) (quoting Schleicher v. State , 718 N.W.2d 440 , 445 (Minn. 2006) ).

2018Moreover, we have repeatedly applied the Knaffla rule "in postconviction proceedings raising constitutional issues of criminal procedure." Lynch v. State , 749 N.W.2d 318 , 321 (Minn. 2008) (quoting Schleicher v. State , 718 N.W.2d 440 , 445 (Minn. 2006) ).

2018Under the Knaffla rule, any claim raised on direct appeal, or in a previous postconviction petition, "will not be considered upon a subsequent petition for postconviction relief." Knaffla , 243 N.W.2d at 741 ; see Jones v. State , 671 N.W.2d 743 , 746 (Minn. 2003) ; see also Minn. Stat. 590.04, subd. 3 (2016) (stating that a court may summarily deny a second or successive petition for similar relief on behalf of the same petitioner).

2018Under the Knaffla rule, any claim raised on direct appeal, or in a previous postconviction petition, "will not be considered upon a subsequent petition for postconviction relief." Knaffla , 243 N.W.2d at 741 ; see Jones v. State , 671 N.W.2d 743 , 746 (Minn. 2003) ; see also Minn. Stat. 590.04, subd. 3 (2016) (stating that a court may summarily deny a second or successive petition for similar relief on behalf of the same petitioner).

2016“There are two exceptions to the Knaffla rule: (1) if a novel legal issue is presented, or (2) if the interests of justice require review.” Taylor v. State, 691 N.W.2d 78, 79 (Minn.2005).

2016“There are two exceptions to the Knaffla rule: (1) if a novel legal issue is presented, or (2) if the interests of justice require review.” Taylor v. State, 691 N.W.2d 78, 79 (Minn.2005).

2024See, e.g., Perry v. State, 731 N.W.2d 143, 147 (Minn. 2007) (finding the interests-of-justice exception to the Knaffla rule was not met when petitioner failed to provide a colorable explanation of why claims were not raised previously); Wright, 765 N.W.2d at 90 (same).

2024See, e.g., Perry v. State, 731 N.W.2d 143, 147 (Minn. 2007) (finding the interests-of-justice exception to the Knaffla rule was not met when petitioner failed to provide a colorable explanation of why claims were not raised previously); Wright, 765 N.W.2d at 90 (same).

2019To prevail on an ineffective-assistance-of-appellate-counsel claim, Onyelobi must show that (1) her counsel's representation on direct appeal "fell below an objective standard of reasonableness," and (2) "there is a reasonable probability that, but for counsel's unprofessional errors, the result of the proceeding would have been different." Strickland v. Washington , 466 U.S. 668 , 688, 694, 104 S.Ct. 2052 , 80 L.Ed.2d 674 (1984) ; see also Dukes v. State , 621 N.W.2d 246 , 252 (Minn. 2001).

2005But, under the second Knaffla exception, a claim of ineffective assistance of trial counsel known but not raised at the time of direct appeal may be brought in a postcon-viction petition if the claim cannot be “evaluated by an appellate court on direct appeal based on the briefs and trial court transcript, without any additional factfind-ing.” Robinson v. State, 567 N.W.2d 491, 495 (Minn.1997); Torres v. State, 688 N.W.2d 569, 572 (Minn.2004) (“A claim of ineffective assistance of trial counsel that can be decided on the basis of the trial court record must be brought on direct appeal and is p

2016Id .; see also Powers v. State, 731 N.W.2d 499, 501 (Minn. 2007) (holding that the Knaffla rule also applies to claims raised or known at the time of earlier postconviction petitions).

2016Id .; see also Powers v. State, 731 N.W.2d 499, 501 (Minn. 2007) (holding that the Knaffla rule also applies to claims raised or known at the time of earlier postconviction petitions).

2018"We review the summary denial of a petition for postconviction relief for an *38 abuse of discretion." Zornes v. State , 903 N.W.2d 411 , 416 (Minn. 2017) (quoting Carridine v. State , 867 N.W.2d 488 , 492 (Minn. 2015) ).

2018"We review the summary denial of a petition for postconviction relief for an *38 abuse of discretion." Zornes v. State , 903 N.W.2d 411 , 416 (Minn. 2017) (quoting Carridine v. State , 867 N.W.2d 488 , 492 (Minn. 2015) ).

2014See Sontoya v. State, 829 N.W.2d 602, 604 (Minn. 2013) (“Given all of these facts, we hold that Sontoya either knew or should have known about 4 trial counsel’s representation of the victim’s cousin, and his claim is therefore barred by the Knaffla rule.”).

2014See Sontoya v. State, 829 N.W.2d 602, 604 (Minn. 2013) (“Given all of these facts, we hold that Sontoya either knew or should have known about 4 trial counsel’s representation of the victim’s cousin, and his claim is therefore barred by the Knaffla rule.”).

2002An exception to the Knaffla rule provides that a claim that was known but not raised may be considered “only where a claim is so novel that it can be said that its legal basis was not reasonably available to counsel at the time the direct appeal was taken.” Case v. State, 364 N.W.2d 797, 800 (Minn.1985).

2002An exception to the Knaffla rule provides that a claim that was known but not raised may be considered “only where a claim is so novel that it can be said that its legal basis was not reasonably available to counsel at the time the direct appeal was taken.” Case v. State, 364 N.W.2d 797, 800 (Minn.1985).

2016Deegan v. State, 711 N.W.2d 89, 94 (Minn. 2006) (quoting Fox v. State, 474 N.W.2d 821, 825 (Minn. 1991)).

2016Deegan v. State, 711 N.W.2d 89, 94 (Minn. 2006) (quoting Fox v. State, 474 N.W.2d 821, 825 (Minn. 1991)).

2016The Knaffla rule “precludes consideration of all claims which appellant should have known but did not raise at the time of an earlier review.” Quick v. State, 757 N.W.2d 278, 280 (Minn. 2008).

2016The Knaffla rule “precludes consideration of all claims which appellant should have known but did not raise at the time of an earlier review.” Quick v. State, 757 N.W.2d 278, 280 (Minn. 2008).

2010Russell v. State, 562 N.W.2d 670, 672 (Minn.1997).

2010Russell v. State, 562 N.W.2d 670, 672 (Minn.1997).

2006Taylor v. State, 691 N.W.2d 78, 79 (Minn.2005) (citing Ives v. State, 655 N.W.2d 633, 636 (Minn.2003)).

2005Ives v. State, 655 N.W.2d 633, 635 (Minn.2003) (citing Knaffla, 309 Minn. at 252 , 243 N.W.2d at 741 ) (“Knaffla rule”).

2025The petitioner must demonstrate “both that counsel’s performance was not objectively reasonable and, but for counsel’s errors, the result of the proceeding would have been different.” Wright v. State, 7 765 N.W.2d 85, 91 (Minn. 2009); see also Strickland v. Washington, 466 U.S. 668 , 690- 94 (1984).

2025The petitioner must demonstrate “both that counsel’s performance was not objectively reasonable and, but for counsel’s errors, the result of the proceeding would have been different.” Wright v. State, 7 765 N.W.2d 85, 91 (Minn. 2009); see also Strickland v. Washington, 466 U.S. 668 , 690- 94 (1984).

2024Knaffla rule”); see also Minn. Stat. § 590.01 , subd. 1 (2022) (“A petition for postconviction relief after a direct appeal has been completed may not be based on grounds that could have been raised on direct appeal of the conviction or sentence.”). “[A] postconviction court may summarily deny a claim that is procedurally barred by the Knaffla rule.” Pearson v. State, 891 N.W.2d 590, 597 (Minn. 2017).

2024Knaffla rule”); see also Minn. Stat. § 590.01 , subd. 1 (2022) (“A petition for postconviction relief after a direct appeal has been completed may not be based on grounds that could have been raised on direct appeal of the conviction or sentence.”). “[A] postconviction court may summarily deny a claim that is procedurally barred by the Knaffla rule.” Pearson v. State, 891 N.W.2d 590, 597 (Minn. 2017).

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.” Buckingham v. State, 799 N.W.2d 229, 231 (Minn. 2011).

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.” Buckingham v. State, 799 N.W.2d 229, 231 (Minn. 2011).

2015We have long held that the Knaffla rule bars any claims that were, or could have been, raised in a prior post-conviction petition. 2 See Wayne v. State, 601 N.W.2d 440, 441 (Minn.1999).

2015We have long held that the Knaffla rule bars any claims that were, or could have been, raised in a prior post-conviction petition. 2 See Wayne v. State, 601 N.W.2d 440, 441 (Minn.1999).

2013See Townsend v. State, 723 N.W.2d 14, 19 (Minn.2006) (stating that the Knaffla rule is “intended to foster” finality and efficiency); Torres v. State, 688 N.W.2d 569, 572 (Minn.2004) (explaining that the Knaffla rule “preserves the goals of finality and efficiency where appropriate and overrides them only where necessary in the interests of justice”).

2013See Townsend v. State, 723 N.W.2d 14, 19 (Minn.2006) (stating that the Knaffla rule is “intended to foster” finality and efficiency); Torres v. State, 688 N.W.2d 569, 572 (Minn.2004) (explaining that the Knaffla rule “preserves the goals of finality and efficiency where appropriate and overrides them only where necessary in the interests of justice”).

2008Robinson v. State, 567 N.W.2d 491, 495 (Minn. 1997); see also Black, 560 N.W.2d at 86 n. 1 (“An exception [to the Knaffla rule] exists ... when the claim is such that the reviewing court needs additional facts to explain the attorney’s decisions.

2008Robinson v. State, 567 N.W.2d 491, 495 (Minn. 1997); see also Black, 560 N.W.2d at 86 n. 1 (“An exception [to the Knaffla rule] exists ... when the claim is such that the reviewing court needs additional facts to explain the attorney’s decisions.

2024Similarly, the interests of justice provide a petitioner with an exception to the Knaffla bar only if the claim has merit and the petitioner “did not deliberately and inexcusably fail to raise the issue on direct appeal.” Deegan, 711 N.W.2d at 94 .

2010In Deegan v. State, we discussed the interests of justice exception to the Knaffla rule. 711 N.W.2d 89, 93-94 (Minn.2006).

2025The supreme court has identified two exceptions to the Knaffla bar: first, the novel-legal-issue exception that applies “if the claim involves an issue so novel that its legal basis was not reasonably 5 available at the time of the direct appeal” and, second, the interests-of-justice exception that applies “as fairness requires if the claim has substantive merit and the petitioner did not deliberately and inexcusably fail to raise the issue in a previous proceeding.” Swaney v. State, 882 N.W.2d 207, 215 (Minn. 2016).

2017The supreme court has recognized two exceptions to the Knaffla rule: (1) “a claim is not barred if the claim involves an issue so novel that its legal basis was not reasonably available at the time of the direct appeal,” and (2) under “the interests-of-justice exception, the court may review a claim as fairness requires if the claim has substantive merit and the petitioner did not deliberately and inexcusably fail to raise the issue in a previous proceeding.” Swaney, 882 N.W.2d at 215 .