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Traylor v. State

Court of Appeals of Minnesota
Jun 7, 2023
No. A22-1801 (Minn. Ct. App. Jun. 7, 2023)

Opinion

A22-1801

06-07-2023

Raymond Joseph Traylor, petitioner, Appellant, v. State of Minnesota, Respondent.


Office of Appellate Courts

Ramsey County District Court File No. 62-CR-14-3082

Considered and decided by Reilly, Presiding Judge; Larkin, Judge; and Slieter, Judge.

ORDER OPINION

Michelle A. Larkin, Judge

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

1. On November 7, 2014, appellant Raymond Joseph Traylor was convicted of two counts of first-degree criminal sexual conduct following a jury trial. State v. Traylor, No. A15-0029, 2016 WL 854578, at *1 (Minn.App. Mar. 7, 2016). The district court imposed consecutive sentences of 201 and 172 months in prison. Id. Traylor filed a direct appeal, and this court affirmed the conviction. Id. at *2-11.

2. Traylor filed his first two petitions for postconviction relief in 2016 and 2017, requesting forensic testing that was purportedly unavailable at the time of trial and alleging that the district court judge who presided over his trial was a "disqualified adjudicator." Traylor v. State, No. A17-0758, 2017 WL 5985471, at *1-2 (Minn.App. Dec. 4, 2017), rev. denied (Minn. Feb. 20, 2018). The postconviction court denied both claims as procedurally barred and without merit. Id. Traylor appealed the denial of the second petition, and this court affirmed. Id. Traylor filed his third postconviction petition in 2018. He asked to withdraw the petition, and the postconviction court dismissed it without prejudice. Traylor filed his fourth postconviction petition in 2020, and the postconviction court dismissed it for lack of service. Traylor appealed, and this court dismissed the appeal as untimely. Traylor v. State, No. A20-0987 (Minn.App. Aug. 25, 2020) (order). Traylor filed his fifth postconviction petition in 2021, alleging in part that the district court judge who presided over his jury trial "fabricated and altered the transcripts omitting them making them incomplete." The postconviction court denied the petition as untimely and procedurally barred. Traylor did not appeal. On March 8, 2022, Traylor filed two documents with the postconviction court requesting correction of the trial record and a new trial. The postconviction court treated these documents as Traylor's sixth petition for postconviction relief, found that petition was lacking proper service, and denied the petition as untimely and procedurally barred. Traylor did not appeal.

3. On August 3, 2022, Traylor filed the underlying postconviction petition- his seventh-asserting that the state's case against him was fabricated, that the district court should have recused itself, that a juror was improperly seated, and that the case against him was part of a government conspiracy and a "frame-up." In replying to the district court's request that the state confirm that it had been served with Traylor's petition, the Ramsey County Attorney's Office requested that the postconviction court deny the petition "for the same reason it denied [Traylor's] previous petitions," that is, because the petition was untimely and procedurally barred. On December 8, 2022, the postconviction court denied the petition on those grounds. Traylor appeals.

4. A person convicted of a crime who claims that a conviction or sentence violated his rights may petition for postconviction relief Minn. Stat. § 590.01, subd. 1(1) (2022). "No petition for postconviction relief may be filed more than two years after the later of (1) the entry of judgment of conviction or sentence if no direct appeal is filed; or (2) an appellate court's disposition of petitioner's direct appeal." Id., subd. 4(a) (2022). There are five exceptions to the two-year statute of limitations. Id., subd. 4(b) (2022). A petitioner bears the burden of establishing that an exception applies. Brocks v. State, 883 N.W.2d 602, 604 (Minn. 2016).

5. In addition to being time-barred, a postconviction petition may be procedurally barred under the Knaffla rule, which provides that "'all claims known but not raised' at the time of direct appeal are barred from consideration in any subsequent petitions for postconviction relief." Cooper v. State, 745 N.W.2d 188, 190-91 (Minn. 2008) (quoting State v. Knaffla, 243 N.W.2d 737, 741 (Minn. 1976)). The Knaffla rule also "includes all claims that the appellant should have known of at the time of appeal." McKenzie v. State, 687 N.W.2d 902, 905 (Minn. 2004). Additionally, the Knaffla rule bars consideration of claims that were raised, or could have been raised, in a previous postconviction petition. Hooper v. State, 838 N.W.2d 775, 787 (Minn. 2013). There are two exceptions to the Knaffla rule: (1) the presentation of a novel legal issue unavailable at the time of the direct appeal; or (2) the interests of justice require review. Brocks v. State, 753 N.W.2d 672, 674-75 (Minn. 2008).

6. We review a district court's decision to deny a postconviction petition for an abuse of discretion. Erickson v. State, 842 N.W.2d 314, 318 (Minn. 2014). A district court abuses its discretion when it has "exercised its discretion in an arbitrary or capricious manner, based its ruling on an erroneous view of the law, or made clearly erroneous factual findings." Reedv. State, 793 N.W.2d 725, 729 (Minn. 2010).

7. This court denied Traylor's direct appeal on March 7, 2016. Traylor, 2016 WL 854578, at *1. As a result, Traylor's deadline to file a postconviction petition was March 7,2018. See Minn. Stat. § 590.01, subd. 4(a). The current postconviction petition- filed in 2022-is clearly past the statutory deadline, and Traylor does not argue that any specific statutory exception to the time bar applies. Further, the majority of the claims in Traylor's current petition have previously been addressed by this court on direct appeal or by the postconviction court in his numerous postconviction proceedings. See Traylor, 2016 WL 854578, at *10 (denying Traylor's.direct appeal claims that the state framed him by planting DNA evidence, that there was no probable cause to proceed to trial, that the prosecutor improperly elicited false testimony from the victims, and that he was the subject of malicious prosecution); Traylor, 2017 WL 5985471, at *2 (affirming denial of Traylor's postconviction claim that the district court judge should have recused himself). To the extent that Traylor's petition raises any new claims, those claims could have been raised previously, and Traylor makes no assertion that an exception to the Knaffla rule applies. Thus, the district court did not abuse its discretion by concluding that Traylor's seventh petition for postconviction relief was untimely and procedurally barred.

8. Traylor argues that because "the state has not challenged this complaint of illegal conviction and imprisonment," he was entitled to a default judgment on his postconviction petition. Traylor is mistaken: the state did challenge his claim for postconviction relief, albeit on grounds unrelated to the merits of his claims. The postconviction court's authority to deny relief on timing and procedural grounds is well-established. Indeed, several of Traylor's prior requests for postconviction relief were denied on such grounds. Moreover, Traylor does not cite and we are not aware of any authority suggesting that the state cannot elect to rely only on the statutory time-bar or the Knaffla rule in opposing a petition for postconviction relief.

9. In sum, the district court did not abuse its discretion by denying relief on the grounds that Traylor's postconviction claims were untimely and Knaffla-barred.

IT IS HEREBY ORDERED:

1. The postconviction 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.


Summaries of

Traylor v. State

Court of Appeals of Minnesota
Jun 7, 2023
No. A22-1801 (Minn. Ct. App. Jun. 7, 2023)
Case details for

Traylor v. State

Case Details

Full title:Raymond Joseph Traylor, petitioner, Appellant, v. State of Minnesota…

Court:Court of Appeals of Minnesota

Date published: Jun 7, 2023

Citations

No. A22-1801 (Minn. Ct. App. Jun. 7, 2023)

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