Dukes v. State

Supreme Court of Minnesota
2001 Minn. LEXIS 19, 2001 WL 83293, 621 N.W.2d 246 (2001)

ELI5:

Rule of Law:

Postconviction claims alleging ineffective assistance of counsel based on unauthorized concessions of guilt are not procedurally barred by a direct appeal failure if they require factfinding regarding attorney-client communications. Additionally, claims of falsified trial testimony must be evaluated under the specific Larrison test rather than the general standard for newly discovered evidence.

Facts:

On April 1, 1994, Derrick Dukes drove accomplices Steve Morrison and Kevin Lewis to Saint Paul.
During two separate incidents, Morrison and Lewis attempted to rob two victims, Chaney and McKinney.
During the robberies, Morrison fired at Chaney, and McKinney was shot and killed by a bullet to the back of the head.
Dukes claims he was unaware of Morrison and Lewis's criminal intentions when he drove them.
Police tracked Dukes' car to a bar where the three men worked as bouncers.
Police subsequently found a .32 caliber pistol, determined to be the murder weapon, in the pocket of Dukes' jacket left at the bar.
Lewis initially confessed and implicated Dukes in the crimes, but later withdrew his guilty plea and refused to testify at Dukes' trial.
A redacted version of Lewis's plea testimony implicating Dukes was admitted into evidence against Dukes.

Procedural Posture:

Dukes was convicted of first-degree murder, attempted murder, and attempted aggravated robbery in the district court.
Dukes appealed his conviction to the Minnesota Supreme Court.
The Minnesota Supreme Court affirmed Dukes' conviction on direct appeal.
Dukes filed a petition for postconviction relief in the district court asserting multiple claims including ineffective assistance and falsified evidence.
The postconviction court denied the petition for relief.

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Issue:

Did the postconviction court err by summarily dismissing the petitioner's claim that trial counsel conceded guilt without consent as procedurally barred, and by applying the standard for 'newly discovered evidence' rather than 'falsified testimony' to a witness recantation?

Opinions:

Majority - Justice Paul H. Anderson

Yes, the postconviction court erred in part regarding the ineffective assistance claim and the standard applied to the recanted testimony. The court held that while claims known at the time of direct appeal are generally barred (the Knaffla rule), claims requiring evidence of attorney-client conversations—such as whether a defendant consented to counsel conceding guilt—cannot be decided on the trial record alone and require a postconviction evidentiary hearing. Therefore, this claim was not waived. Furthermore, regarding the witness's recantation, the lower court incorrectly applied the four-prong Rainer test for newly discovered evidence. The court should have applied the three-prong Larrison test specifically designed for cases involving falsified testimony, which focuses on whether the jury 'might' have reached a different conclusion without the false testimony.

Analysis:

This decision clarifies the scope of the Knaffla rule in Minnesota, establishing that ineffective assistance claims involving off-record attorney-client communications (specifically regarding consent to concede guilt) generally survive the procedural bar of a direct appeal. This ensures defendants have a forum to air grievances that depend on facts not present in a trial transcript. Additionally, the case reinforces the distinction between generic 'newly discovered evidence' and specific 'falsified testimony.' By mandating the Larrison test for recantations, the court lowers the burden for defendants seeking a new trial based on perjury, requiring only that the jury 'might' have reached a different conclusion, rather than the 'probability' of acquittal required for other new evidence.

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