Jermaine Ferguson v. State of Minnesota

Summary

The Supreme Court of Minnesota held that Jermaine Ferguson's second postconviction petition was not barred because it included a sworn affidavit from the allegedly recanting witness, unlike the unsworn memorandum submitted with his first petition. The court concluded that the postconviction court should have held an evidentiary hearing to evaluate the credibility and genuineness of the recantation under the Larrison test. The court reversed and remanded for an evidentiary hearing.

Holdings

1. The second petition was not barred under State v. Knaffla or Minnesota Statutes section 590.04, subdivision 3 because it was supported by a signed and notarized affidavit from Green himself, materially different from the prior unsworn hearsay memorandum, and the prior affirmance had been without prejudice.
2. A postconviction court must conduct an evidentiary hearing when the petition alleges facts that, if proven, could entitle the petitioner to relief, and doubts about whether to conduct the hearing should be resolved in favor of the requesting party.
3. Ferguson alleged facts that, if proven, could satisfy the first and second Larrison prongs, and the third prong is not an absolute condition precedent; therefore, the postconviction court erred by summarily denying the petition without an evidentiary hearing.

Questions Presented

1. Whether Ferguson's second postconviction petition was barred under State v. Knaffla or Minnesota Statutes section 590.04, subdivision 3.
2. Whether the petition alleged facts that, if proven, could satisfy the Larrison test for a new trial based on recanted testimony and therefore required an evidentiary hearing.
3. Whether the postconviction court abused its discretion by summarily denying the petition without evaluating Green's credibility at an evidentiary hearing.

Disposition

reversed_and_remanded