Postconviction Relief in Minnesota

How It Differs From a Direct Appeal

A direct appeal reviews the trial record for legal error within tight deadlines. A postconviction petition is different:

• It can raise issues that aren't in the record — things the appellate court couldn't see from transcripts alone.
• It allows the development of new facts through a petition and, in some cases, an evidentiary hearing.
• It's the usual vehicle when the direct-appeal window has passed or when the issue requires evidence beyond the trial record.

What Postconviction Relief Can Address

Common grounds include:

• Ineffective assistance of counsel — where the prior lawyer's performance fell below acceptable standards and it affected the outcome. (See ineffective assistance of counsel.)
• Newly discovered evidence that wasn't available at trial and could change the result.
• Constitutional violations not previously addressed.
• Prosecutorial misconduct or suppressed exculpatory evidence.
• Sentencing issues in certain circumstances.

The Two-Year Time Limit

Under Minn. Stat. § 590.01, subd. 4, a postconviction petition generally must be filed within two years of the later of the entry of judgment of conviction or sentence, or an appellate court's disposition of the direct appeal. There are limited statutory exceptions — for example, a newly recognized and retroactive constitutional rule, newly discovered evidence that meets strict requirements, or where the interests of justice require it — but those exceptions are narrow and must themselves be invoked promptly. Do not assume an exception applies; treat the two-year clock as firm and confirm your deadline right away.

The Knaffla Bar: Raise It or Lose It

The most common trap in Minnesota postconviction practice is the Knaffla rule, from State v. Knaffla. Under it, claims that were raised — or that were known and could have been raised — on direct appeal are barred from being brought later in a postconviction petition. The principle is finality: you generally get one full and fair chance to raise an issue. There are recognized exceptions (for instance, a claim whose legal basis was not reasonably available earlier, or where fairness requires review and the petitioner did not deliberately and inexcusably fail to raise it), but they are limited.

What this means for you: the choices made during the direct appeal directly shape what postconviction relief is still available later. That's why appellate and postconviction strategy should be coordinated from the start — bringing a claim in the wrong order, or too late, can close the door permanently.

The Process

A postconviction case begins with a written petition filed in the district court where you were convicted, setting out the grounds and supporting facts. The State responds, and the court decides whether to hold an evidentiary hearing — required unless the petition, files, and record conclusively show you are entitled to no relief. To earn a hearing, the petition must allege specific facts that, if proven, would entitle you to relief, not bare conclusions. If the court denies the petition, you generally have 60 days to appeal that denial under Minn. R. Crim. P. 28.02. There's no filing fee for a postconviction appeal under section 590.06, and there is a limited statutory right to counsel in postconviction proceedings under section 611.25.

What Relief Looks Like

If a petition succeeds, the court can vacate the conviction, order a new trial, modify the sentence, or grant other appropriate relief depending on the issue. Postconviction relief is demanding — courts don't grant it lightly — but for the right issue, especially one outside the trial record, it can be the only avenue left.

Key Terms

• Postconviction petition: A request under Chapter 590 to challenge a conviction or sentence after direct appeal.
• Knaffla bar: The rule barring claims that were or could have been raised on direct appeal.
• Evidentiary hearing: A hearing to develop facts not in the trial record.
• Ineffective assistance of counsel: A common postconviction ground based on the prior attorney's deficient performance.
• Two-year limit: The general deadline for filing under § 590.01, subd. 4, with limited exceptions.