Friday, August 5, 2016

Post Conviction Claims Knaffla Barred

Fairbanks v. State, Minn.S.Ct., 7/20/2016.  A jury convicted Mr. Fairbanks of first degree murder and nine other felonies associated with the homicide of a deputy sheriff.  The supreme court affirmed his murder conviction and all by one of the other felony convictions in 2014. In this post conviction petition Mr. Fairbanks says that he didn't actually cause the death of the deputy sheriff.  He based this claim by asserting - as he apparently did at trial - that in part the family's decision to refuse further medical treatment caused the death.  That is, Mr. Fairbanks is saying that the family committed euthanasia.

Now, before trial the defense and the state struck a deal whereby the defense wouldn't make the euthanasia claim and the state would neither argue about the definition of euthanasia nor ask the medical examiner whether euthanasia caused the deputy's death.  Mr. Fairbanks signed off on this arrangement on the record.  On direct appeal, Mr. Fairbanks did not raise the causation issue.  Justice G. Barry Anderson concluded that Mr. Fairbanks' causation claim was barred under Knaffla because he could have raised the claim on direct appeal but failed to do.  Mr. Fairbanks did not suggest that either of the Knaffla exceptions applied.


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