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Arredondo v. State, 754 N.W.2d 566

Facts

Gilberto Arredondo was convicted of first-degree felony murder for the 1993 death of Ramon Guardiola. He was indicted on multiple charges, including first-degree premeditated murder and second-degree intentional murder. The jury found him guilty of first-degree felony murder and other charges, but not guilty of first-degree premeditated murder. After his conviction was affirmed on direct appeal, Arredondo filed a petition for postconviction relief, alleging various claims including ineffective assistance of counsel.

Arredondo was indicted for first-degree premeditated murder, Minn.Stat. § 609.185 (1) (2000); first-degree felony murder, Minn.Stat. § 609.185 (3) (1996); second-degree intentional murder, Minn.Stat. § 609.19 (1) (1994); and second-degree felony murder, Minn.Stat. § 609.19 (2) (1994), for Ramon Guardiola's death.

Issue

Whether the claims in Arredondo's postconviction petition were barred by the Knaffla rule and whether he received ineffective assistance of appellate counsel.

1. certain claims in defendant's petition were barred by Knaffla rule;

Rule

Under the Knaffla rule, claims raised in a direct appeal and claims known but not raised in the direct appeal will not be considered in a postconviction proceeding. Additionally, to succeed on an ineffective assistance of appellate counsel claim, a petitioner must show that counsel's performance fell below an objective standard of reasonableness.

Under State v. Knaffla, 309 Minn. 246, 243 N.W.2d 737 (1976), claims raised by the petitioner in a direct appeal and claims known but not raised in the direct appeal will not be considered in a postconviction proceeding.

Analysis

The court analyzed Arredondo's claims under the Knaffla rule, determining that many of his claims were barred because they could have been raised during his direct appeal. The court also evaluated the performance of appellate counsel, concluding that counsel could have reasonably determined that the claims regarding legally inconsistent verdicts and hearsay evidence would not prevail, thus not constituting ineffective assistance.

Because an inconsistent verdict would have been evident from the trial record, Arredondo either knew or should have known of this issue at the time of his direct appeal.

Conclusion

The Supreme Court affirmed the postconviction court's denial of Arredondo's petition for relief, concluding that his claims were either barred or lacked merit.

We therefore hold that Arredondo's ineffective assistance of appellate counsel claim is without merit and that the postconviction court did not err when it denied relief as to this claim.

Who won?

The State prevailed in the case as the Supreme Court affirmed the postconviction court's decision to deny Arredondo's petition for relief, finding that his claims were barred or without merit.

Affirmed.

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