Perry v. State

Summary

The Supreme Court of Minnesota affirmed the summary denial of Leon Perry’s petition for postconviction relief. The court held that his equal protection and ineffective assistance of counsel claims were procedurally barred under the Knaffla rule and that no exception applied.

Holdings

1. The Knaffla rule barred Perry's Fourteenth Amendment equal-protection claim because he knew or should have known of the claim before his direct appeal.
2. Neither exception applied because Perry's equal-protection claim was not novel and fairness did not require review of a claim he should have raised more than nine years earlier.
3. The Knaffla rule barred Perry's ineffective-assistance claim because he knew of the facts underlying it and knew that ineffective assistance could be raised on direct appeal.

Questions Presented

1. Whether Perry's Fourteenth Amendment equal-protection challenge to the racial composition of the grand jury was procedurally barred under the Knaffla rule.
2. Whether either exception to the Knaffla rule applied to permit review of Perry's equal-protection claim.
3. Whether Perry's newly raised ineffective-assistance-of-trial-counsel claim was procedurally barred under the Knaffla rule.
4. Whether the postconviction court abused its discretion by summarily denying the petition.

Disposition

affirmed