"Any doubts about whether to conduct an evidentiary hearing should be resolved in favor of the defendant seeking relief." State v. Nicks, 831 N.W.2d 493, 504 (Minn. 2013).
This court reviews the postconviction court's factual determinations under a clearly erroneous standard, and this court will not disturb those findings unless they are unsupported by the record. Id.; see State v. Nicks, 831 N.W.2d 493, 503-04 (Minn. 2013). The postconviction court's legal conclusions are reviewed de novo.
When an appellate court reviews a postconviction court's denial of relief on a claim of ineffective assistance of counsel, it considers only "the court's factual findings that are supported in the record." State v. Nicks, 831 N.W.2d 493, 503-04 (Minn. 2013). The legal implication of those facts on the ineffective-assistance claim is reviewed de novo.
"Any doubts about whether to conduct an evidentiary hearing should be resolved in favor of the defendant seeking relief." State v. Nicks, 831 N.W.2d 493, 504 (Minn. 2013). A reviewing court "must consider [the petitioner's] allegations in the light most favorable to him, and also consider the files and records of the proceeding, including the State's arguments."
"[T]o receive an evidentiary hearing on a postconviction claim of ineffective assistance of counsel, a defendant is required to allege facts that, if proven by a fair preponderance of the evidence, would satisfy the two-prong test announced in [Strickland]." State v. Nicks, 831 N.W.2d 493, 504 (Minn. 2013) (quotation omitted). Under Strickland, a defendant must prove that (1) "counsel's representation fell below an objective standard of reasonableness" and (2) "there was a reasonable probability that, but for counsel's errors, the result of the proceeding would have been different." Id.
"[W]e review a denial of a petition for postconviction relief, including a denial of relief without an evidentiary hearing, for an abuse of discretion." State v. Nicks, 831 N.W.2d 493, 503 (Minn. 2013). Legal issues raised in a postconviction petition are reviewed de novo, and factual issues are reviewed for whether the record sufficiently sustains the postconviction court's findings.
Generally, we will not review attacks on counsel's trial strategy. See State v. Nicks, 831 N.W.2d 493, 506 (Minn. 2013). And we apply a strong presumption that an attorney's "performance falls within the wide range of reasonable professional assistance."
The district court "abuses its discretion when its decision is based on an erroneous view of the law or is against logic and the facts in the record." State v. Nicks, 831 N.W.2d 493, 503 (Minn. 2013) (quotation omitted)
We review a postconviction court's denial of ineffective-assistance-of-counsel claims by considering the factual findings supported by the record and by conducting "de novo review of the legal implication of those facts on the ineffective assistance claim." State v. Nicks, 831 N.W.2d 493, 503-04 (Minn. 2013).
To be entitled to an evidentiary hearing on a postconviction ineffective-assistance-of-counsel claim, a petitioner must "allege facts that, if proven by a fair preponderance of the evidence, would satisfy the two-prong test" established in Strickland. State v. Nicks, 831 N.W.2d 493, 504 (Minn. 2013) (quotation omitted)