interests-of-justice exception in Minnesota

2026See Sanchez, 816 N.W.2d at 559 (rejecting the argument that “an interests-of-justice claim based on ineffective assistance of counsel can arise only once a petitioner subjectively knows that his counsel was ineffective” (emphasis omitted)).

2025“The interests-of-justice exception is ‘triggered by an injustice that caused the petitioner to miss the primary deadline in subdivision 4(a)’ and ‘not the substantive claims in the petition.’” Caldwell v. State, 976 N.W.2d 131 , 141 (Minn. 2022) (quoting Sanchez, 816 N.W.2d at 557 ).

2016The interests-of-justice exception applies only in “exceptional circumstances.” Gassler v. State, 787 N.W.2d 575, 586 (Minn. 2010).

2016The interests-of-justice exception applies only “in exceptional situations.” Gassler v. State, 787 N.W.2d 575, 586 (Minn. 2010).

2019For example, in Rickert v. State , we held that the petitioner's otherwise untimely petition satisfied the interests-of-justice exception where the untimeliness was caused by a third party's dilatory conduct. 795 N.W.2d 236 , 242 (Minn. 2011).

2016A petition is “frivolous” for purposes of the interests-of-justice exception, “if it is perfectly apparent, without argument, that the petition is without merit.” Rickert, 795 N.W.2d at 241 (quoting Gassler v. State, 787 N.W.2d 575 (Minn.2010)).

2017These factors do not form a “rigid” test, and “courts are not required to examine each [] factor in every case asserting the interests-of-justice exception.” Id. at 608 .

2016Even if Bolstad’s claim qualified for the interests-of-justice exception, the statute'also requires that the . claim be brought within 2 years of the date the “claim arises.” Minn.Stat. § 590.01, subd. 4(c) (2014); see Carlton v. State, 816 N.W.2d 590, 600 (Minn.2012) (noting that the court should consider whether a petitioner has complied with the 2-year time limit under subdivision 4(c) prior to determining whether the petitioner has qualified for an exception under subdivision 4(b)(2)). “[A] petitioner’s claim under [the interests-of-justice exception] arises when the petitioner knew or sho

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).

2016The interests-of-justice exception requires that the petition not be “frivolous,” and that its belated consideration be in the “interests of justice.” Wallace v. State, 820 N.W.2d 843, 849 (Minn.2012); see also Minn.Stat. § 590.01, subd. 4(b)(5) (requiring that the petitioner establish “to the satisfaction of the court that the petition is not frivolous and is in the interests of justice”).

2016Interests-of-justice exception “To satisfy the interests-of-justice exception, . . . a petitioner must satisfy two requirements: (1) that the petition is not frivolous, and (2) that the petition is in the interests of justice.” Wallace v. State, 820 N.W.2d 843, 849 (Minn. 2012) (quotations omitted).

2015See id.; see also Deegan v. State, 711 N.W.2d 89, 94 (Minn. 2006) (stating that the interests-of-justice exception is “quite narrow” and that “the grounds for postconviction relief are substantially limited once a direct appeal has been taken”).

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

2024“The interests-of-justice exception is available only in rare and exceptional situations.” Hooper v. State, 888 N.W.2d 138, 142 (Minn. 2016).

2019See Hooper , 888 N.W.2d at 142 (stating that a petitioner's claim under the interests-of-justice exception "must relate to an injustice that delayed the filing of the petition").

2016See Greer v. State, 836 N.W.2d 520, 523 (Minn.2013); Sanchez, 816 N.W.2d at 560 .

2016Greer v. State, 836 N.W.2d 520, 522 (Minn. 2013).

2016The interests-of-justice exception “is reserved for exceptional cases.” Taylor v. State, 874 N.W.2d 429, 431 (Minn. 2016) (quotation omitted). [I]n deciding whether to grant relief in the interests of justice, courts should weigh the degree to which the party alleging error is at fault for that error, the degree of fault assigned to the party defending the alleged error, and whether some fundamental unfairness to the defendant needs to be addressed. [Courts] have also acted in the interests of justice when necessary to protect the integrity of judicial proceedings.

2016This exception to the two-year time limit “is reserved for exceptional cases.” Taylor v. State, 874 N.W.2d 429, 431 (Minn. 2016) (quotation 6 omitted).

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).

2019See Swaney , 882 N.W.2d at 215-16 (concluding that the claim did not satisfy the interests-of-justice exception because petitioner "offer[ed] no argument as to why his failure to raise this issue in his pro se brief on direct appeal was not deliberate and inexcusable").

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).

2016The supreme court recently clarified that the interests-of-justice exception “relate[s] to the reason the petition was filed after the 2-year time limit in subdivision 4(a), not the substantive claims in the petition,” and that “the interests-of-justice exception is triggered by an injustice that caused the petitioner to miss the primary deadline in subdivision 4(a), not the substance of the petition.” Sanchez, 816 N.W.2d at 557 (emphasis in original) (cited in Wayne v. State, 866 N.W.2d 917, 920 (Minn. 2015), and Brown v. State, 863 N.W.2d 781, 788 (Minn. 2015)).

2015The supreme court recently clarified that the interests-of-justice exception “relate[s] to the reason the petition was filed after the 2-year time limit in subdivision 8 4(a), not the substantive claims in the petition,” and that “the interests-of-justice exception is triggered by an injustice that caused the petitioner to miss the primary deadline in subdivision 4(a), not the substance of the petition.” Sanchez, 816 N.W.2d at 557 (cited in Wayne v. State, 866 N.W.2d 917, 920 (Minn. 2015), and Brown v. State, 863 N.W.2d 781, 788 (Minn. 2015)).

2017A claim under the interests-of-justice exception “arises on the date of an event that establishes a right to relief in the interests of justice.” Bee Yang v. State, 805 N.W.2d 921, 925 (Minn. App. 2011), review denied (Minn. Aug. 7, 2012).

2016A claim under the interests-of-justice exception arises “on the date of an event that establishes a right to relief in the interests of justice.” Yang v. State, 805 N.W.2d 921, 925 (Minn. App. 2011), review denied (Minn. Aug. 7, 2012). 2 Minnesota courts determine when an interests-of-justice claim arises using an objective “knew or should have known” standard.

2024For the interests-of-justice exception to apply, “the petitioner must not have deliberately and inexcusably failed to raise the issue 4 on direct appeal.” Powers, 695 N.W.2d at 374 (quotation omitted).

2009In addition, for the interests of justice exception to apply, the appellant “must not have 'deliberately and inexcusably’ failed to raise the issue on direct appeal.’’ Powers v. State (.Powers I), 695 N.W.2d 371, 374 (Minn.2005) (internal citation omitted).

2024See Griffin, 883 N.W.2d at 286 (noting that for an unraised claim there are two exceptions to 9 a petition for postconviction relief must have substantive merit and petitioner must not have deliberately and inexcusably delayed in bringing the claim.

2024See Griffin, 883 N.W.2d at 286 (noting that for an unraised claim there are two exceptions to 9 a petition for postconviction relief must have substantive merit and petitioner must not have deliberately and inexcusably delayed in bringing the claim.

2019See Andersen , 913 N.W.2d at 428 (viewing the facts in the light most favorable to the petitioner and holding that they "fail to establish an injustice that delayed the filing of [the] ... petition"); see also Minn. Stat. § 590.03 (2018) ("The court shall liberally construe the petition and any amendments thereto and shall look to the substance thereof and waive any irregularities or defects in form.").

2019To invoke this exception, "the claim must relate to an injustice that delayed the filing of the petition, not to the substantive merit of the petition." Andersen , 913 N.W.2d at 428 (internal quotation marks omitted).

2016Here, even if Butters’s brief may be construed as arguing the interests- of-justice exception, that exception is usually limited to unique situations when “the petitioner did not deliberately and inexcusably fail to raise the issue on direct appeal.” 4 Roby v. State, 531 N.W.2d 482, 484 (Minn. 1995) (quotation omitted).

2015The interests- 3 of-justice exception is generally limited to unique situations where the petitioner did not “deliberately and inexcusably fail to raise the issue on direct appeal.” Roby v. State, 531 N.W.2d 482, 484 (Minn. 1995) (quotation omitted).

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

2005See Fox v. State, 474 N.W.2d 821, 825 (Minn.1991).

2016The supreme court recently clarified that the interests-of-justice exception “relate[s] to the reason the petition was filed after the 2-year time limit in subdivision 4(a), not the substantive claims in the petition,” and that “the interests-of-justice exception is triggered by an injustice that caused the petitioner to miss the primary deadline in subdivision 4(a), not the substance of the petition.” Sanchez, 816 N.W.2d at 557 (emphasis in original) (cited in Wayne v. State, 866 N.W.2d 917, 920 (Minn. 2015), and Brown v. State, 863 N.W.2d 781, 788 (Minn. 2015)).

2015The supreme court recently clarified that the interests-of-justice exception “relate[s] to the reason the petition was filed after the 2-year time limit in subdivision 8 4(a), not the substantive claims in the petition,” and that “the interests-of-justice exception is triggered by an injustice that caused the petitioner to miss the primary deadline in subdivision 4(a), not the substance of the petition.” Sanchez, 816 N.W.2d at 557 (cited in Wayne v. State, 866 N.W.2d 917, 920 (Minn. 2015), and Brown v. State, 863 N.W.2d 781, 788 (Minn. 2015)).

2016The Interests-of-Justice Exception “Under the interests-of-justice exception, a court may hear an untimely petition for postconviction relief if ‘the petitioner establishes to the satisfaction of the court that the petition is not frivolous and is in the interests of justice.’” Id. at 292 (quoting Minn. Stat. § 590.01 , subd. 4(b)(5) (2012)).

2016The Interests-of-Justice Exception “Under the interests-of-justice exception, a court may hear an untimely petition for postconviction relief if ‘the petitioner establishes to the satisfaction of the court that the petition is not frivolous and is in the interests of justice.’” Id. at 292 (quoting Minn. Stat. § 590.01 , subd. 4(b)(5) (2012)).

2025Unless a statutory exception applies, Minn. Stat. § 590.01 , subd. 4(b), a petition filed outside the statute of limitations may be summarily denied, Colbert v. State, 870 N.W.2d 616, 622 (Minn. 2015).

2016“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 . . . .” Colbert, 870 N.W.2d at 626 .

2016Even assuming that the interests-of-justice exception remains applicable to this petition, however, a viable claim “must have substantive merit and must be asserted without deliberate or inexcusable delay.” Id. at 8 .

2016Andersen v. State, 830 N.W.2d 1, 8 (Minn. 2013).

2007Carney, 692 N.W.2d at 891 .

2006See Azure, 700 N.W.2d at 448-49 ; Carney v. State, 692 N.W.2d 888, 891 (Minn.2005).

2025Because restitution is part of a sentence, a defendant may challenge a restitution order through a motion to correct sentence under Minnesota Rule of Criminal Procedure 27.03, subdivision 9, if the defendant is “challeng[ing] the court’s legal authority to award restitution” and “the motion does not impact the underlying conviction.” Evans v. State, 880 N.W.2d 357, 359-60 (Minn. 2016).

2024See, e.g., Crow v. State, 923 N.W.2d 2, 9-10 (Minn. 2019) (explaining that there are two exceptions the Knaffla procedural bar: the novel-legal-issue exception and the interests-of-justice exception).

2019See Tyree Leland Jackson v. State , 927 N.W.2d 308 , 313 (Minn. 2019) (affirming the summary denial of postconviction relief "because Lafler was decided more *907 than 2 years before [Tyree Jackson] filed his petition"). 5 Jackson also asserts that the facts alleged in his petition are sufficient to invoke the interests-of-justice exception of Minnesota Statutes section 590.01, subdivision 4(b)(5).