State v. Riley
568 N.W.2d 518 (1997)
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Rule of Law:
A postconviction petition filed after the statutory time limit may not be heard under the 'newly discovered evidence' exception if the evidence was known to the petitioner at the time of trial, is inadmissible hearsay without sufficient corroboration, or fails to establish the petitioner's actual innocence by a clear and convincing standard.
Facts:
- The night before a triple murder, victims Troy Tholkes and James M. Walters were with Adrian Dominic Riley at a Minneapolis residence.
- On the morning of May 23, 1995, James Greenwood, who lived with Walters, saw Tholkes and an unidentified black man at the farmhouse.
- Later that day, a witness saw a white man and a black man asking where to buy ammunition, and another witness heard gunshots near the farmhouse.
- After the gunshots, a black man was seen driving Tholkes' car asking for directions back to Minneapolis.
- Greenwood returned home that evening to find Treesa Woods dead inside the farmhouse; police later found the bodies of Walters and Tholkes outside.
- All three victims died from gunshot wounds inflicted by a 9 mm handgun; a box for such a gun was found empty at the scene.
- Police arrested Riley two days later and recovered a Smith & Wesson 9 mm handgun at the house where he was staying.
- Riley's fingerprints were found on a cup, a stereo cabinet, and a beer bottle at the crime scene, as well as on the recovered handgun.
Procedural Posture:
- A grand jury indicted Adrian Dominic Riley on three counts of first-degree murder and three counts of second-degree murder.
- A jury in Carver County district court (trial court) found Riley guilty on all six counts.
- The trial court entered convictions on the three counts of first-degree murder and imposed three consecutive life sentences.
- Riley, as appellant, appealed to the Minnesota Supreme Court, which affirmed the convictions on direct appeal in `Riley I`.
- Years later, Riley filed a first petition for postconviction relief in district court, which was summarily denied.
- The Minnesota Supreme Court, in `Riley II`, affirmed the denial of the first petition, holding it was time-barred.
- In 2011, Riley filed a second petition for postconviction relief and a motion for additional fingerprint and DNA testing in the district court (postconviction court).
- The postconviction court summarily denied the second petition as time-barred and denied the motion for testing.
- Riley, as appellant, appealed the denial of his second petition and motion to the Minnesota Supreme Court.
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Issue:
Does a defendant's postconviction petition, supported by affidavits containing hearsay confessions of a deceased third party, satisfy the statutory exceptions for 'newly discovered evidence' or 'interests of justice' when the evidence lacks independent corroboration and the substance of the claim was known to the defendant at the time of trial?
Opinions:
Majority - Justice Dietzen
No. A defendant's petition does not satisfy the statutory exceptions because the proffered evidence is not 'newly discovered,' constitutes inadmissible hearsay, and fails to establish actual innocence. The court held that Riley's second postconviction petition was time-barred and did not qualify for an exception. The 'newly discovered evidence' exception failed for three reasons: 1) The evidence was not new, as an affiant claimed to have told Riley about the alleged third-party confession on the night of the murders, meaning Riley knew of it at the time of his trial. 2) The alleged confessions of the deceased third party, Joseph Papasodora, were inadmissible hearsay. Under Minn. R. Evid. 804(b)(3), a statement against interest offered to exculpate an accused is only admissible if 'corroborating circumstances clearly indicate the trustworthiness of the statement,' which was absent here as there was no independent evidence linking Papasodora to the crime. 3) The evidence did not establish Riley's actual innocence by a clear and convincing standard, given the substantial trial evidence of his guilt, including eyewitness testimony describing a black perpetrator and his fingerprints on the murder weapon. The 'interests of justice' exception also failed because it is reserved for exceptional cases, and Riley offered no excuse for the 16-year delay in raising the claim. Finally, the court denied the motion for new forensic testing because Riley failed to show that the technology was unavailable at the time of his trial as required by statute.
Analysis:
This decision reinforces the high procedural hurdles for postconviction relief, emphasizing the principle of finality in criminal judgments. The court's stringent application of the corroboration requirement for the 'statement against interest' hearsay exception makes it exceedingly difficult to introduce unverified third-party confessions after a conviction. This case serves as a clear precedent that claims of actual innocence must be supported by admissible, credible, and compelling evidence, not merely by uncorroborated allegations that could have been raised years earlier. The ruling narrows the avenues for prisoners to reopen long-settled cases, particularly when the new claims rely on the testimony of deceased declarants.
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