Summary
The Minnesota Supreme Court affirmed the denial of William Jeffrey McDonough’s fifth petition for postconviction relief. The court held that the evidence offered to support a claim of false trial testimony did not satisfy the Larrison test, and that the postconviction court properly denied an amended claim without an additional evidentiary hearing. The court also held that McDonough’s constitutional challenge to the first-degree murder statute was time-barred.
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Practice areas
Questions Presented
- Whether the postconviction court abused its discretion by denying relief based on alleged newly discovered evidence that the trial witness gave false testimony.
- Whether the postconviction court erred by summarily denying the amendment to the fifth petition without holding an additional evidentiary hearing.
- Whether McDonough's constitutional challenge to the first-degree murder statute was barred by the statutory postconviction time limit.
Holdings
- The postconviction court properly denied relief because its finding that the trial witness did not testify falsely was not clearly erroneous, and McDonough therefore failed to satisfy the Larrison test.
- Although the postconviction court mischaracterized the amendment as a separate amended petition subject to summary dismissal under the successive-petition provision, summary denial was proper because the allegations were legally insufficient to establish entitlement to relief even if proven.
- The constitutional claim was time-barred because a petition invoking the interests-of-justice exception must be filed within two years after the claim arises, and McDonough did not explain why he could not have known of the claim before the relevant deadline.
Key quotations
“(1) the court must be reasonably well-satisfied that the trial testimony was false; (2) without the false testimony, the jury might have reached a different conclusion; and (3) the petitioner was taken by surprise at trial or did not know of the falsity until after trial.” (426)
“The first two prongs are compulsory, while the last prong is relevant but not a condition precedent to relief.” (426)
Factual background
In 1999, Steven Crenshaw and Reginald Rodgers were shot during a drive-by shooting, resulting in Rodgers's death and injuries to Crenshaw. At trial, Crenshaw testified that he recognized McDonough as the shooter. In his fifth postconviction petition, McDonough relied on affidavits alleging that Crenshaw had privately recanted his identification and claimed that police had coerced his testimony, but Crenshaw denied making those statements and reaffirmed his trial testimony at the evidentiary hearing.
Procedural history
McDonough's convictions for first-degree murder and attempted first-degree murder were affirmed on direct appeal. The postconviction court denied four earlier petitions, held an evidentiary hearing on the fifth petition, denied the petition and its later amendment, and rejected McDonough's constitutional challenge as untimely. The Minnesota Supreme Court affirmed.