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Edwards v. State

Court of Appeals of Minnesota
Jun 4, 2024
No. A23-1159 (Minn. Ct. App. Jun. 4, 2024)

Opinion

A23-1159

06-04-2024

Johnny Earl Edwards, petitioner, Appellant, v. State of Minnesota,Respondent.


Anoka County District Court File No. 02-CR-17-3290

Considered and decided by Schmidt, Presiding Judge; Slieter, Judge; and Wheelock, Judge.

ORDER OPINION

SARAH I. WHEELOCK JUDGE

BASED ON THE FILE, RECORD, AND PROCEEDINGS, AND BECAUSE:

1. Appellant Johnny Earl Edwards challenges the district court's denial of his petition for postconviction relief, contending that the court abused its discretion by dismissing his petition as time-barred sua sponte without providing him notice and an opportunity to be heard.

A postconviction petition is untimely if it is filed more than two years after "an appellate court's disposition of petitioner's direct appeal." Minn. Stat. § 590.01, subd. 4(a)(2) (2022).

2. On June 6, 2022, Edwards petitioned for relief from his December 11, 2017, second-degree murder conviction, contending that he was entitled to relief because his guilty plea was constitutionally inaccurate and because he was sentenced by a biased judicial officer. The postconviction court dismissed his petition as Knaffla-barred,determining that Edwards had the opportunity to raise these challenges in his direct appeal, State v. Edwards, No. A18-1632 (Minn.App. June 17, 2019), rev. denied (Minn. Sept. 17, 2019), and unjustifiably failed to do so. We reversed the postconviction court's Knaffla-based dismissal and remanded the case to the district court. Edwards v. State, No. A22-11221, 2023 WL 3161216, at *2 (Minn.App. Apr. 19, 2023). On remand, the postconviction court determined sua sponte that Edwards's petition was untimely and dismissed the petition for that reason and because it failed on the merits. Edwards appeals.

Under State v. Knaffla, "claims that were raised on direct appeal, or were known or should have been known but were not raised on direct appeal, are procedurally barred" unless the claim is novel or unless "the interests of fairness and justice require relief." 243 N.W.2d 737, 741 (Minn. 1976).

3. Appellate courts review a postconviction court's decision to dismiss a postconviction petition for an abuse of discretion. Colbert v. State, 870 N.W.2d 616, 621 (Minn. 2015). In doing so, we consider the legal issues de novo but limit our review of factual matters to whether the district court's findings are supported by sufficient evidence. Brown v. State, 863 N.W.2d 781, 786 (Minn. 2015).

4. A postconviction court has the inherent authority to manage its docket in a manner that ensures "economy of time and effort for itself, for counsel, and for litigants." Weitzel v. State, 883 N.W.2d 553, 560 (Minn. 2016). As part of this authority, a postconviction court may dismiss a petition as untimely, even when the state fails to raise timeliness as an affirmative defense to the petition. Id. But before ruling on the timeliness issue, a postconviction court "must give notice to the parties and afford them the opportunity to be heard." Id. Because the postconviction court here failed to provide Edwards with notice and an opportunity to be heard before it decided the timeliness issue, the postconviction court abused its discretion.

5. Edwards asks that we remedy this abuse of discretion by reversing not only the postconviction court's timeliness decision but also its decision on the merits of his plea and sentencing claims. His request runs counter to the decision in Weitzel, in which the supreme court determined that reversing and remanding the timeliness issue was necessary under identical circumstances to "vindicate [the appellant's] procedural due process rights." Id. It reached this conclusion notwithstanding the fact that the postconviction court also dismissed Weitzel's arguments on their merits. See id. at 555 (acknowledging the postconviction court's alternative conclusion that "Weitzel had failed to establish that his claim had substantive merit"). The same remedy is therefore required here.

IT IS HEREBY ORDERED:

1. The district court's order denying appellant's postconviction petition is reversed and this matter is remanded for further proceedings consistent with this opinion.

2. Pursuant to Minn. R. Civ. App. P. 136.01, subd. 1(c), this order opinion is nonprecedential, except as law of the case, res judicata, or collateral estoppel.


Summaries of

Edwards v. State

Court of Appeals of Minnesota
Jun 4, 2024
No. A23-1159 (Minn. Ct. App. Jun. 4, 2024)
Case details for

Edwards v. State

Case Details

Full title:Johnny Earl Edwards, petitioner, Appellant, v. State of…

Court:Court of Appeals of Minnesota

Date published: Jun 4, 2024

Citations

No. A23-1159 (Minn. Ct. App. Jun. 4, 2024)