Opinion
A22-0095
09-13-2022
Deonte Darnell Lawson, petitioner, Appellant, v. State of Minnesota, Respondent.
Hennepin County District Court File No. 27-CR-18-5059
Considered and decided by Gaïtas, Presiding Judge; Cochran, Judge; and Bryan, Judge.
ORDER OPINION
JEFFREY M. BRYAN, JUDGE
BASED ON THE FILE, RECORD, AND PROCEEDINGS, AND BECAUSE:
1. This court previously affirmed appellant Deonte Lawson's conviction of two counts of first-degree criminal sexual conduct, in violation of Minnesota Statutes section 609.342, subdivisions 1(c), (f)(i) (2016), and one count of kidnapping, in violation of Minnesota Statutes section 609.25, subdivision 1(2) (2016). State v. Lawson, No. A19-1259, 2020 WL 4743519 (Minn.App. Aug. 17, 2020), rev. denied (Minn. Nov. 17, 2020). In the direct appeal, Lawson argued that the district court plainly erred when it instructed the jury regarding venue and when it imposed a life sentence without the possibility of parole. In his pro se supplemental brief, Lawson argued that the outcome of the case "should have been different due to evidence that was not presented." Id. at *1 n.1. This court rejected the arguments, concluding that the alleged error in the venue jury instruction was not plain error, id. at *2-3; there was sufficient evidence to support the sentence imposed, id. at *4; and Lawson had forfeited the arguments made in the supplemental brief, id. at *1 n.1.
2. Lawson petitioned for postconviction relief in September 2021. The district court denied the petition without an evidentiary hearing. The district court concluded that Lawson's claims were procedurally barred under State v. Knaffla, 243 N.W.2d 737, 741 (Minn. 1976). Lawson appeals.
3. A postconviction petition brought after a direct appeal has been completed may not raise claims that either were raised or could have been raised on direct appeal. Minn. Stat. § 590.01, subd. 1 (2020); Knaffla, 243 N.W.2d at 741. This rule, known as the Knaffla rule, procedurally bars all claims that were known or should have been known at the time of direct appeal. Colbert v. State, 870 N.W.2d 616, 626 (Minn. 2015). The district court may deny a claim that is Knaffla-barred without holding an evidentiary hearing. Id. at 622. We review a decision to deny a postconviction petition based on Knaffla for an abuse of discretion. Quick v. State, 692 N.W.2d 438, 439 (Minn. 2005).
4. The district court did not abuse its discretion in this case when it denied Lawson's postconviction petition without an evidentiary hearing. Lawson's petition claimed that the jury in his case was not "an impartial jury of [his] peers," but instead was composed of women biased against him. Lawson also argued that the prosecutor committed misconduct by not selecting an impartial jury during voir dire and by purposefully eliciting false testimony from Lawson's codefendant. The district court correctly determined that arguments regarding the make-up of a jury and prosecutorial misconduct were known to Lawson and could have been raised during Lawson's direct appeal.
5. Finally, although there are two exceptions to the Knaffla rule, Swaney v. State, 882 N.W.2d 207, 215 (Minn. 2016) (identifying an exception when the claim involves a novel issue whose legal basis was not available at the time of direct appeal and a second exception based on the interests of justice), Lawson did not assert that either exception applies here and neither exception appears to apply based on our review.
IT IS HEREBY ORDERED:
1. The district court's order is affirmed.
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.