Wayne v. State

Appellant was convicted of murder and sentenced to life in prison. The Supreme Court affirmed the conviction. After unsuccessfully filing four petitions for postconviction relief, Appellant filed a "Motion for DNA Analysis" under Minn. Stat. 590.01(1)(a) requesting DNA testing of the victim's underwear. The postconviction court construed Appellant's motion as his fifth petition for postconviction relief and found the petition was procedurally barred. The Supreme Court affirmed without addressing the issue of whether the postconviction court erred when it treated Appellant's motion as a petition for postconviction relief, holding (1) Appellant's motion for DNA testing failed to satisfy the requirements of Minn. Stat. 590.01(1)(a) as a matter of law; and (2) even if it was proper to treat Appellant's motion as a petition for postconviction relief, Appellant's claim was time-barred. View "Wayne v. State" on Justia Law