Summary
The Minnesota Supreme Court affirmed the denial of David Doppler’s third petition for postconviction relief following his conviction for first-degree premeditated murder. The court held that claims concerning his confession and an affidavit from Rhonda Hanestad were procedurally barred, and that other alleged newly discovered or recanted evidence did not satisfy the applicable Rainer or Larrison standards. A partial dissent would have ordered an evidentiary hearing concerning an affidavit asserting Doppler’s innocence.
Topics
Practice areas
Questions Presented
- Whether the postconviction court abused its discretion by denying an evidentiary hearing concerning affidavits from Albert Logan and Rhonda Hanestad.
- Whether affidavits and testimony from Heather Doppler and Josh Doppler constituted newly discovered or recanted evidence warranting a new trial.
- Whether Doppler's challenge to the use of his confession was barred under the Knaffla rule.
Holdings
- The postconviction court did not abuse its discretion by denying an evidentiary hearing because Logan's affidavit did not clearly recant his trial testimony, was unsupported by facts establishing Doppler's entitlement to relief, and did not show that the jury likely would have reached a different result.
- Doppler's newly discovered evidence claim based on Hanestad's affidavit was barred under the Knaffla rule because the claim was raised or could have been raised in an earlier proceeding.
- The affidavits and testimony of Heather Doppler and Josh Doppler did not satisfy the requirements for a new trial based on newly discovered evidence or recanted testimony.
- Doppler's challenge to the specificity and use of his confession was Knaffla-barred.
Key quotations
“To receive a new trial based on newly-discovered evidence, a petitioner must show:” (872)
“Under the Larrison test, when deciding whether to grant petitioner's request for a new trial based on recanted testimony, the postconviction court should consider three factors:” (872)
Factual background
David Doppler was convicted of first-degree premeditated murder after Michael Sargent was shot four times near Little Blackhoof Lake. Doppler confessed to shooting Sargent and repeated the confession at trial, while also claiming that Sargent came at him with a knife. Doppler later submitted affidavits asserting that witnesses had information implicating his brother Keith or establishing Doppler's innocence, but the postconviction court found the statements doubtful and concluded that they would not likely have changed the trial result.
Procedural history
Doppler was convicted of first-degree premeditated murder in 1996. The Minnesota Supreme Court affirmed the conviction and denial of his first postconviction petition alleging ineffective assistance of trial counsel, and later affirmed denial of his second petition alleging ineffective assistance of appellate counsel as procedurally barred. In his third petition, Doppler asserted that his confession should have been excluded, that intoxication affected his account of the shooting, and that newly discovered evidence warranted a new trial. The postconviction court denied the confession and intoxication claims as procedurally barred, held an evidentiary hearing concerning some newly discovered evidence, and denied relief; the Supreme Court affirmed.