Carlos Heard, Appellant, vs. State of Minnesota, Respondent

Summary

The court held that the decisions defining the mental-state element of third-degree depraved-mind murder announced new substantive rules that apply retroactively to final convictions. Because the petitioner filed his first postconviction petition invoking those decisions within two years after they were issued, the petition qualified for the statutory new-interpretation-of-law exception and was not independently barred by the procedural rule governing claims omitted from earlier proceedings. The court reversed and remanded for consideration of the merits of the petitioner’s challenge to his conviction.