Munt v. State, Minn.S.Ct., 6/15/2016. A jury convicted Mr. Munt of four counts of first degree murder and various other crimes, arising out of the shooting death of his ex-wife and the kidnapping of his three children. He pled not guilty by reason of mental illness. The supreme court upheld his convictions, read here.
Mr. Munt eventually filed this post conviction petition. The post conviction court concluded that the petition was untimely under the limitations provisions of the post conviction statute. Minn.Stat. 590.01, subd. 4(a)(2) and that it did not meet any of the statutory exceptions to that two year limitations period.
Chief Justice Gildea first chastises the post conviction court for wrongly concluding that the petition was untimely. It was not; the post conviction court failed to include the ninety days window after disposition of his direct appeal.
Mr. Munt argued that the trial court had given an incorrect instruction on circumstantial evidence. It's not entirely clear just what instruction Mr. Munt wanted the trial court to have given. Chief Justice Gildea cites to State v. Caldwell, 803 N.W.2d 373 (Minn. 2011), which talks about assuming that the jury believed the state's witnesses and disbelieved any evidence to the contrary. This may not be what the current law on sufficiency of circumstantial evidence is, but it doesn't matter as the court concludes that Mr. Munt's claim is procedurally barred under Knaffla.
Mr. Munt also argued that his sentence of life without possibility of release is unconstitutional under Miller v. Alabama. Mr. Munt said that failure to extend Miller to adults denies him equal protection. The Chief states that Miller applies only to juveniles and thus not to Mr. Munt who was thirty-five years old at the time of the crimes.