Post Conviction Claims are Knaffla Barred.

Davis v. State, Minn.S.Ct., 6/15/2016.  Mr. Davis is serving a life sentence for the felony murder of Armando Calix.  Mr. Davis appealed that conviction and sentence, in which he raised some fifteen claims.  The court denied relief on all of those claims.

He then filed a post conviction petition in which thirteen of the fifteen claims he presented were duplicate claims raised on direct appeal. Under the Knaffla rule those claims are procedurally barred. Neither the post conviction court nor Justice Stras addressed whether the statutory adoption of the Knaffla rule, Minn.Stat. 590.04, subd 3 is either a separate basis for denial of the post conviction petition; or has superseded Knaffla.  Justice Stras affirms the denial of relief on the other two claims - sufficiency of evidence, and an evidentiary ruling - because those claims were or should have been known to Mr. Davis at the time of his direct appeal.  Justice Stras also declined to address either the two Knaffla exceptions, or the limitations exceptions in the statute.