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10 Minnesota opinions name it 2 courts 2004–2024 2 in the last five years
The cases below were cited by Minnesota courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
Quick v. Stategreen2 sentences2015Quick v. State, 692 N.W.2d 438, 439 (Minn. 2005). 2014Quick v. State, 692 N.W.2d 438, 439 (Minn. 2005). | 3 | 3 |
Martin v. Stategreen2 sentences2017However, an appellant “cannot recharacterize a claim previously litigated to avoid the Knaffla procedural bar.” Martin v. State, 825 N.W.2d 734 , 745–46 (Minn. 2013) (disallowing appellant’s attempt to restate “an evidentiary issue in terms of ineffective assistance of trial counsel”) (citation omitted). 2016“A defendant cannot recharacterize a claim previously litigated to avoid the Knaffla procedural bar.” Martin v. State, 825 N.W.2d 734, 745 (Minn. 2013). | 1 | 2 |
Crow v. Stategreen2 sentences2024See, 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). 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). | 1 | 1 |
Derrick Trevor Griffin v. State of Minnesotagreen2 sentences2024Griffin v. State, 883 N.W.2d 282, 286 (Minn. 2016). 2024See Griffin, 883 N.W.2d at 286 (noting that a procedurally barred claim will not be considered in a subsequent proceeding). 6 Accordingly, the State argues the district court abused its discretion because it did not address Knaffla in its order granting postconviction relief. | 1 | 1 |
Leake v. Stategreen1 sentence2015The Knaffla procedural bar is subject to two exceptions: (1) a claim known but not raised on direct appeal is not barred “if the claim’s novelty was so great that its legal basis was not reasonably available when direct appeal was taken,” and (2) a claim is not barred “when fairness so requires and when the petitioner did not deliberately and inexcusably fail to raise the issue on direct appeal.” Leake v. State, 737 N.W.2d 531, 535 (Minn. 2007) (quotation omitted). | 1 | 1 |
Black v. Stategreen1 sentence2013See Black v. State, 560 N.W.2d 83, 86 (Minn.1997) (“We will not allow [the petitioner] to avoid the Knaffla limitation simply by restating an evidentiary issue in terms of ineffective assistance of trial counsel.”); White v. State, 711 N.W.2d 106, 110 (Minn.2006). | 1 | 1 |
White v. Stategreen1 sentence2013See Black v. State, 560 N.W.2d 83, 86 (Minn.1997) (“We will not allow [the petitioner] to avoid the Knaffla limitation simply by restating an evidentiary issue in terms of ineffective assistance of trial counsel.”); White v. State, 711 N.W.2d 106, 110 (Minn.2006). | 1 | 1 |
Deegan v. Stategreen2 sentences2006We have also recognized that the exceptions to the Knaffla procedural bar are “quite narrow,” Deegan v. State, 711 N.W.2d 89, 94 (Minn.2006), and we have said that we ought not to apply those exceptions so as to permit the exceptions to “swallow the rule.” Townsend v. State, 723 N.W.2d 14, 19 , (Minn.2006). 2006We have also recognized that the exceptions to the Knaffla procedural bar are "quite narrow," Deegan v. State, 711 N.W.2d 89, 94 (Minn.2006), and we have said that we ought not to apply those exceptions so as to permit the exceptions to "swallow the rule." Townsend v. State, 723 N.W.2d 14, 19 , (Minn.2006). | 1 | 1 |
State v. Smallwoodgreen1 sentence2004See State v. Smallwood, 594 N.W.2d 144, 157 (Minn.1999) (holding that a reviewing court “will not interfere with a trial court’s discretion in sentencing unless the sentence is disproportionate to the offense.”). *561 Neal reiterates the proportionality .requirement, and it does not present a “novel legal claim” necessary to overcome the Knaffla procedural bar. | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Minnesota. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Massaro v. United States
green
2 sentences2016Butters argues that the district court erred by ruling that his claims were Knaffla- barred, citing Massaro v. United States, 538 U.S. 500 , 123 S. Ct. 1690 (2003). 2016Butters argues that the district court erred by ruling that his claims were Knaffla- barred, citing Massaro v. United States, 538 U.S. 500 , 123 S. Ct. 1690 (2003). | 1 | 2016–2016 |
Townsend v. State
green
2 sentences2006We have also recognized that the exceptions to the Knaffla procedural bar are “quite narrow,” Deegan v. State, 711 N.W.2d 89, 94 (Minn.2006), and we have said that we ought not to apply those exceptions so as to permit the exceptions to “swallow the rule.” Townsend v. State, 723 N.W.2d 14, 19 , (Minn.2006). 2006We have also recognized that the exceptions to the Knaffla procedural bar are "quite narrow," Deegan v. State, 711 N.W.2d 89, 94 (Minn.2006), and we have said that we ought not to apply those exceptions so as to permit the exceptions to "swallow the rule." Townsend v. State, 723 N.W.2d 14, 19 , (Minn.2006). | 1 | 2006–2006 |
Neal v. State
green
2 sentences2004Appellant relies on the Minnesota Supreme Court case of Neal v. State, 658 N.W.2d 536 (Minn.2003), and argues that, because Neal was unavailable at the time of his direct appeal, his claims bypass the Knaffla procedural bar. 2 Neal involved an offender convicted and sentenced on a kidnapping charge where he restrained the victim for a short period of time, did not remove the victim from the scene, and confined the victim solely to facilitate the commission of the crime of robbery. 2004Id. at 540-41 . | 1 | 2004–2004 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.