early hearing (Minnesota) · Go Syfert
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early hearing in Minnesota

9 Minnesota opinions name it 2 courts 1971–2025 1 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.

Followed or applied (6)

CaseFollowedCited
Erickson v. Stategreen
minn · 2014 · cited in 2 Minnesota opinions naming this issue, 2015–2015
2 sentences

2015When a petition for postconviction relief is filed, “the court shall promptly set an early hearing on the petition and response thereto, and promptly determine the issues” “[u]nless the petition and the files and records of the proceeding conclusively show that the petitioner is entitled to no relief.” Minn. Stat. § 590.04 , subd. 1 (2014); see Erickson v. State, 842 N.W.2d 314, 318 (Minn. 2014).

2015Lastly, appellant argues that the district court abused its discretion when it denied his request for an evidentiary hearing based on the newly discovered evidence and interest-of-justice exceptions.1 When a petition for postconviction relief is filed, “the court shall promptly set an early hearing on the petition and response thereto, and promptly determine the issues” unless the “petition and the files and records of the proceeding conclusively show that the petitioner is entitled to no relief.” Minn. Stat. § 590.04 , subd. 1; see Erickson v. State, 842 N.W.2d 314, 318 (Minn. 2014).

22
Bobo v. Stategreen
minn · 2012 · cited in 1 Minnesota opinions naming this issue, 2025–2025
1 sentence

2025A district court may summarily deny a petition without holding an evidentiary hearing when “the petitioner alleges facts that, if true, are legally insufficient to grant the requested relief.” State v. Sardina-Padilla, 7 N.W.3d 585, 602–03 (Minn. 2024); Reese v. State, 992 N.W.2d 373 , 378 (Minn. 2023); see also Bobo v. State, 820 N.W.2d 511, 517 (Minn. 2012).

11
State v. Knafflagreen
minn · 1976 · cited in 1 Minnesota opinions naming this issue, 2016–2016
2 sentences

2016Minn. Stat. § 590.04 , subd. 1 (2014). “[W]here direct appeal has once been taken, all matters raised therein, and all claims known but not raised, will not be considered upon a subsequent petition for postconviction relief.” State v. Knaffla, 309 Minn. 246, 252 , 243 N.W.2d 737, 741 (1976); see also Minn. Stat. § 590.04 , subd. 3 (2014) (“The court may summarily deny a second or successive petition for similar relief on behalf of the same petitioner and may summarily deny a petition when the issues raised in it have previously been decided by [an appellate court] in the same case.”).

2016Minn. Stat. § 590.04 , subd. 1 (2014). “[W]here direct appeal has once been taken, all matters raised therein, and all claims known but not raised, will not be considered upon a subsequent petition for postconviction relief.” State v. Knaffla, 309 Minn. 246, 252 , 243 N.W.2d 737, 741 (1976); see also Minn. Stat. § 590.04 , subd. 3 (2014) (“The court may summarily deny a second or successive petition for similar relief on behalf of the same petitioner and may summarily deny a petition when the issues raised in it have previously been decided by [an appellate court] in the same case.”).

11
Roby v. Stategreen
minn · 1995 · cited in 1 Minnesota opinions naming this issue, 2003–2003
1 sentence

2003A petitioner must allege facts that “if proven by a fair preponderance of the evidence, entitle him to relief.” State v. Rhodes, 627 N.W.2d 74, 86 (Minn.2001) (quoting Roby v. State, 531 N.W.2d 482, 483 (Minn.1995)).

11
State v. Rhodesgreen
minn · 2001 · cited in 1 Minnesota opinions naming this issue, 2003–2003
1 sentence

2003A petitioner must allege facts that “if proven by a fair preponderance of the evidence, entitle him to relief.” State v. Rhodes, 627 N.W.2d 74, 86 (Minn.2001) (quoting Roby v. State, 531 N.W.2d 482, 483 (Minn.1995)).

11
Fratzke v. Stategreen
minn · 1990 · cited in 1 Minnesota opinions naming this issue, 1996–1996
1 sentence

1996Minn.Stat. § 590.04, subd. 1 (1996) (emphasis added); see also Fratzke, 450 N.W.2d at 102-103 (holding that an evidentiary hearing is not required unless facts are alleged which, if proved, would entitle a petitioner to the requested relief).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Minnesota. Read the followed side critically anyway.

Also cited on this issue (5)

CaseCitedYears
State v. Nicks green
minn · 2013
2 sentences

2015The threshold standard for an evidentiary hearing is lower than that for a new trial; “[a]ny doubts about whether to conduct an evidentiary hearing should be resolved in 8 favor of the defendant seeking relief.” Nicks, 831 N.W.2d at 504 .

2015The threshold standard for an evidentiary hearing is lower than that for a new trial; “[a]ny doubts about whether to conduct an evidentiary hearing should be resolved in favor of the defendant seeking relief.” Nicks, 831 N.W.2d at 504 .

22015–2015
State of Minnesota v. Angel Ignacio Sardina-Padilla green
minn · 2024
1 sentence

2025A district court may summarily deny a petition without holding an evidentiary hearing when “the petitioner alleges facts that, if true, are legally insufficient to grant the requested relief.” State v. Sardina-Padilla, 7 N.W.3d 585, 602–03 (Minn. 2024); Reese v. State, 992 N.W.2d 373 , 378 (Minn. 2023); see also Bobo v. State, 820 N.W.2d 511, 517 (Minn. 2012).

12025–2025
Woodruff v. 2008 Mercedes green
minnctapp · 2013
1 sentence

2015“Any doubts about whether to conduct an evidentiary hearing should be resolved in favor of the defendant seeking relief.” Nicks, 831 N.W.2d 9 at 504 .

12015–2015
State v. Wells Fargo & Co. green
· 1920
2 sentences

1985State v. Wells Fargo & Co., 146 Minn. 444 , 179 N.W. 221 (1920).

1985State v. Wells Fargo & Co., 146 Minn. 444 , 179 N.W. 221 (1920).

11985–1985
In re Improvement of Lake of the Isles Park neutral
minn · 1922
2 sentences

1971In In re Improvement of Lake of the Isles Park, 152 Minn. 29 , 188 N. W. 54 , the issue arose in the assessment for construction of the parkway around Lake of the Isles and Lake Calhoun, two Minneapolis lakes which are connected by a lagoon.

1971In In re Improvement of Lake of the Isles Park, 152 Minn. 29 , 188 N. W. 54 , the issue arose in the assessment for construction of the parkway around Lake of the Isles and Lake Calhoun, two Minneapolis lakes which are connected by a lagoon.

11971–1971

Statutes the citing opinions construe

MN § Minn. Stat. § 590.04 (7) MN § Minn. Stat. § 590.01 (5) MN § Minn. Stat. § 480A.08 (4)

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.

Where else courts name it

CA 32 (1892–2024) NY 19 (1897–2012) IL 15 (1903–2020) AL 15 (1985–2014) FL 11 (1876–2020) WA 10 (1909–2019) MO 10 (1876–1991) PA 10 (1908–2020) MN 9 (1971–2025) MI 8 (1879–2010) TX 7 (1924–2007) NC 6 (1885–1976) ND 6 (1940–2017) OR 6 (1898–2022) WI 6 (1881–1980) MD 6 (1911–2005) OK 5 (1925–1985) GA 5 (1909–2019) DC 5 (1981–1995) HI 5 (1929–2014) NJ 5 (1974–2013) DE 5 (1932–1994) LA 4 (1921–2000) MA 4 (1895–1977) WV 4 (1904–2020) IA 4 (1932–2020) CT 4 (1919–1995) KS 4 (1935–1997) OH 3 (1980–2025) VA 3 (1852–1852) NM 3 (2014–2014) AR 2 (2001–2018) SD 2 (1907–1998) NV 2 (1935–2021) SC 2 (1942–1999) CO 2 (1915–1995) IN 2 (1929–1967) ME 2 (1977–2000) AZ 2 (1975–1976) ID 2 (1903–1916) VT 2 (1850–1976)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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