The district court correctly determined that the juror's affidavit did not satisfy the requirements of newly discovered evidence because it was inadmissible in any proceeding as a matter of law. See Miles v. State, 840 N.W.2d 195, 203 (Minn. 2013) (stating that the district court properly rejected a claim of newly discovered evidence because the evidence was substantively inadmissible). We have long held that "a jury's deliberations must remain inviolate and its verdict may not be reviewed or set aside on the basis of affidavits or testimony concerning that which transpired in the course of those deliberations."
District court evidentiary rulings are subject to an abuse of discretion standard on review. Miles v. State , 840 N.W.2d 195, 204 (Minn. 2013). But we use a de novo review standard in determining whether the admission of evidence violates a defendant's rights under the Confrontation Clause.
He also stated that the person shooting from Caldwell's vehicle was in the front passenger seat. Because "[t]he postconviction court is in the best position to evaluate witness credibility," Miles v. State, 840 N.W.2d 195, 201 (Minn. 2013), we will not disturb the postconviction court's findings of fact if "reasonable evidence" supports those findings. State v. Evans, 756 N.W.2d 854, 870 (Minn. 2008) (citation omitted) (internal quotation marks omitted).
We review the denial of a postconviction petition for an abuse of discretion. Miles v. State , 840 N.W.2d 195, 200 (Minn. 2013). A postconviction court abuses its discretion when the court’s "decision is based on an erroneous view of the law or is against logic and the facts in the record."
The district court is in the best position to evaluate witness credibility, and we defer to those determinations absent a clear error. Miles v. State , 840 N.W.2d 195, 201 (Minn. 2013). The district court considered Griffin’s testimony at the evidentiary hearing and did not find it credible.
1997). If the defendant fails to establish any one of these requirements, we need not discuss any of the others. Miles v. State , 840 N.W.2d 195, 201 (Minn. 2013).Here, two of the affiants swear that they spoke with Mosley's defense counsel before trial. Specifically, the affiants allege that they were contacted by defense counsel, and that they told counsel and the defense investigator they were willing to testify, but they were not called as witnesses.
Rainer , 566 N.W.2d at 695 (emphasis added). Because the requirements of the Rainer test are stated in the conjunctive, Pearson must satisfy all four. Miles v. State , 840 N.W.2d 195, 201 (Minn. 2013). Pearson contends that the record does not support the postconviction court's finding that J.B.'s testimony was doubtful.
A postconviction court “abuse[s] its discretion when the postconviction court's ‘decision is based on an erroneous view of the law or is against logic and the facts in the record.’ ” Miles v. State, 840 N.W.2d 195, 200 (Minn.2013) (quoting Riley v. State, 819 N.W.2d 162, 167 (Minn.2012) ).
The testimony of Madison and Hill is questionable at best, and the postconviction court's finding that the witnesses lacked credibility was not clearly erroneous.See Miles v. State, 840 N.W.2d 195, 201 (Minn.2013) (“The postconviction court is in the best position to evaluate witness credibility and so we defer to the court's credibility determinations.”). We therefore hold that the postconviction court did not abuse its discretion when it denied Carridine's newly discovered evidence claim.
Race v. State, 504 N.W.2d 214, 217–18 (Minn.1993). Because “[t]he postconviction court is in the best position to evaluate witness credibility,” Miles v. State, 840 N.W.2d 195, 201 (Minn.2013), we review its credibility determinations under the clearly erroneous standard. State v. Ali, 855 N.W.2d 235, 245 (Minn.2014).