Larry Jonnell Gilbert v. State of Minnesota, A21-1560, Supreme Court, January 17, 2024

Summary

The court held that a district court abuses its discretion when it grants postconviction relief without expressly deciding whether a properly raised Knaffla procedural bar applies and without explaining why the claim is not barred. It further held that Gilbert's false-testimony claim was barred because the issue was known or reasonably discoverable during his direct appeal and was not raised. The court also concluded that the interests-of-justice exception did not apply because Gilbert failed to show that the earlier omission was excusable.