Coleman and Noor Apply Retroactively; Knaffla Does Not Bar First Petitions Raising New Interpretations of Law

Introduction

In Carlos Heard v. State of Minnesota, 22 N.W.3d 154 (Minn. 2025), the Minnesota Supreme Court resolved two important questions at the intersection of homicide law and postconviction procedure:

Substantive criminal law: Whether State v. Coleman, 957 N.W.2d 72 (Minn. 2021), and State v. Noor, 964 N.W.2d 424 (Minn. 2021), announced new, retroactive rules narrowing the mens rea for third-degree “depraved-mind” murder under Minn. Stat. § 609.195(a).
Postconviction practice: Whether a petitioner who relies on such a retroactive new interpretation of law in the first postconviction filing after the decision must also independently overcome the procedural bar in State v. Knaffla, 243 N.W.2d 737 (Minn. 1976).

The Court held that Coleman and Noor are new substantive rules that apply retroactively to final convictions and that the petitioner need not separately satisfy Knaffla when the petition is the first filed within two years of the new interpretation and the petitioner shows retroactive applicability. The case was reversed and remanded to consider whether those rulings undermine Heard’s third-degree murder conviction.

Background

In 2011, a jury convicted Carlos Heard of third-degree depraved-mind murder for the shooting death of his brother during a struggle over a gun, and of second-degree intentional murder for the killing of another person after Heard gained control of the firearm. He received consecutive prison sentences: 313 months for second-degree intentional murder and 180 months for third-degree murder. His direct appeal challenged impeachment rulings only and was denied; four subsequent postconviction petitions also failed.

In his fifth postconviction petition, filed in March 2023—within two years of Coleman (March 31, 2021) and Noor (September 15, 2021)—Heard argued those decisions narrowed the mens rea for third-degree depraved-mind murder and apply retroactively, rendering his third-degree conviction invalid. The district court and court of appeals rejected the petition as untimely; they characterized Coleman as mere clarification and Noor as reaffirmation, not new rules. The Supreme Court granted review.

Summary of the Opinion

New Rules Identified: The Court held that both Coleman and Noor announced new rules, not predictable extensions of prior precedent.
Substantive and Retroactive: These new rules are substantive because they define and narrow the mental-state element of the offense, altering the scope of conduct punishable under § 609.195(a). As substantive rules, they apply retroactively to final convictions.
Timeliness Under § 590.01: Heard’s petition was timely under Minn. Stat. § 590.01, subd. 4(b)(3) and (c), which allow petitions based on a new interpretation of law filed within two years of the decision announcing the new rule if retroactively applicable.
Relationship to Knaffla: A petitioner who brings the first postconviction petition after a new, retroactively applicable interpretation of state law is announced is not separately required to satisfy Knaffla.
Disposition: Reversed and remanded for the district court to assess whether Coleman and Noor affect the validity of Heard’s third-degree murder conviction.

Analysis

Precedents Cited and Their Influence

Teague v. Lane, 489 U.S. 288 (1989): Provides the federal retroactivity framework distinguishing new versus old rules and substantive versus procedural rules. The Court assumed, without deciding, that Teague governs retroactivity for new interpretations of state statutory law in this context, because both parties and lower courts proceeded under Teague.
Edwards v. Vannoy, 593 U.S. 255 (2021): Eliminates the federal “watershed” procedural rule exception. The Minnesota Supreme Court noted but did not resolve its continued vitality under Minnesota law because the decision here rests on substantive, not procedural, rules.
Schriro v. Summerlin, 542 U.S. 348 (2004): Clarifies that substantive rules alter the range of conduct or class of persons punishable, while procedural rules regulate how guilt is determined. The Court uses this lens to categorize Coleman and Noor.
Johnson v. State, 916 N.W.2d 674 (Minn. 2018); Aili v. State, 963 N.W.2d 442 (Minn. 2021); State v. Meger, 901 N.W.2d 418 (Minn. 2017): Minnesota cases applying Teague’s framework and explaining when rules are “new” (i.e., when the outcome was not dictated by precedent and reasonable jurists could disagree).
State v. Coleman, 957 N.W.2d 72 (Minn. 2021): Clarified that third-degree depraved-mind murder requires a mental state of reckless disregard of human life—indifference to the loss of life an eminently dangerous act could cause—and invalidated the then-existing pattern jury instruction that misstated the mental-state element.
State v. Noor, 964 N.W.2d 424 (Minn. 2021): Held that depraved-mind murder requires generalized indifference to human life that cannot exist when the defendant’s conduct is directed with particularity at the person killed; it expressly overruled State v. Mytych, 194 N.W.2d 276 (Minn. 1972), which had permitted third-degree convictions in such targeted scenarios.
State v. Knaffla, 243 N.W.2d 737 (Minn. 1976): Establishes the procedural bar against relitigating claims known but not raised on direct appeal. The Court clarifies that Knaffla does not separately bar a first postconviction petition that properly invokes the § 590.01, subd. 4(b)(3) new-interpretation-of-law exception and shows retroactivity.
Osborne v. State, 715 N.W.2d 436 (Minn. 2006) and Stiles v. State, 716 N.W.2d 327 (Minn. 2006): Emphasize that defendants cannot be expected to foresee new rules and that a new rule announced after a direct appeal may present an “unknown” claim not barred by Knaffla.
Additional citations: Pearson v. State, 891 N.W.2d 590 (Minn. 2017) (abuse-of-discretion review of postconviction denials); Daniel v. City of Minneapolis, 923 N.W.2d 637 (Minn. 2019) (reluctance to overrule precedent); State v. Hall, 931 N.W.2d 737 (Minn. 2019) (cites Mytych), illustrating the unsettled landscape before Noor.

Legal Reasoning

Choice of retroactivity framework: The Court assumed, without deciding, that Teague’s federal framework applies to new interpretations of state statutory law when analyzing the § 590.01, subd. 4(b)(3) exception. This assumption avoided deciding a broader doctrinal question not briefed for resolution.
“New rule” determination:
- Coleman: Although the Coleman opinion used the word “clarify,” the Court emphasized that Minnesota precedent had “no clear directive” on the mental-state element for third-degree depraved-mind murder and that pervasive confusion persisted, aided by an erroneous pattern instruction. Because reasonable jurists could (and did) disagree about whether the statute required a reckless act or a mental state of reckless disregard, Coleman “announced a new rule” under Teague—it was not a predictable extension dictated by existing precedent.
- Noor: By expressly overruling Mytych and rejecting the view that third-degree murder can rest on conduct directed at a specific person, Noor also announced a new rule. The pre-Noor authorities, including court of appeals reasoning and the State’s own reliance on Mytych, showed the issue was “susceptible to debate among reasonable minds.”
Substantive versus procedural: The Court held the Coleman/Noor rules are substantive because they define and narrow the mens rea element of third-degree murder—i.e., they alter the range of conduct and class of persons punishable under § 609.195(a). This directly affects who can be convicted of that offense, not merely the procedures used to find guilt.
Retroactive applicability: Because the rules are substantive, they apply retroactively to final convictions under Teague and Minnesota precedent.
Timeliness under § 590.01, subd. 4(b)(3) and (c): Heard filed within two years of Coleman and Noor, and he established retroactive applicability. His petition therefore satisfied the statute’s new-interpretation-of-law exception to the two-year bar.
Interplay with Knaffla: The State argued that even if timely under § 590.01, Heard needed to circumvent Knaffla. The Court rejected this additional hurdle for a first postconviction petition invoking a new, retroactive interpretation of law: imposing Knaffla here would nullify the statutory exception by requiring petitioners to have raised a claim before the new rule existed. Minnesota law does not expect defendants to foresee new rules, and new rules post-appeal can present claims not barred by Knaffla.

Impact

Homicide charging and trial strategy: Prosecutors must align third-degree depraved-mind murder charges with the clarified mens rea:
- Generalized indifference to human life is required; it is incompatible with conduct directed with particularity at a single victim.
- The mental state focuses on the defendant’s reckless disregard of human life, not merely that the act itself was reckless.
This will likely reduce third-degree charges in single-victim, targeted shootings or stabbings and refocus charging toward second-degree intentional murder or manslaughter, depending on proof.
Pattern jury instructions and trial courts: Following Coleman, the criminal jury instructions have been revised. Trial courts must ensure instructions capture the mental state accurately and avoid suggesting that a reckless manner of acting alone suffices.
Postconviction landscape and final convictions: Defendants with final third-degree depraved-mind murder convictions may seek relief if:
- Within two years of a qualifying new interpretation (here, Coleman and Noor) under § 590.01, subd. 4(c); and
- They can show that the new rule is retroactively applicable (as this opinion confirms) and affects their conviction (e.g., the act was directed at a specific person, or the instructions/evidence did not establish indifference to human life as Coleman requires).
The Court’s limitation on Knaffla in this context streamlines access to merits review for such first petitions.
Case-specific remedies: Relief might include vacatur of the third-degree conviction and resentencing on remaining counts. Where the third-degree count carried a consecutive sentence, as in Heard, this can materially reduce aggregate terms.
Doctrinal clarifications left open:
- The Court assumed, without deciding, that Teague applies to state law interpretations for purposes of § 590.01; future cases may address that definitively.
- The status of the federal “watershed” exception under Minnesota law post-Edwards remains unresolved.
Administrative effects: Expect increased postconviction filings leveraging Coleman/Noor within the statutory window. Courts will need to conduct fact-intensive reviews to determine whether the defendant’s conduct demonstrated generalized indifference versus targeted action, and whether the jury was properly instructed on the required mental state.

Complex Concepts Simplified

Depraved-mind murder (third degree) mental state: The State must prove the defendant acted with reckless disregard for human life—indifferent to whether someone might die—when performing an eminently dangerous act. After Noor, this does not cover acts aimed at one specific person.
“Directed with particularity” versus “generalized indifference”:
- “Directed with particularity” means the defendant targeted a specific individual (e.g., aiming and firing at one person).
- “Generalized indifference” involves endangering people broadly without caring who might be harmed (e.g., firing into a crowd, driving wildly in a populated area).
New rule versus old rule (Teague): A rule is “new” if it was not dictated by prior precedent—i.e., reasonable judges could disagree before the new case was decided. New substantive rules (those changing the scope of criminal liability) apply retroactively; new procedural rules generally do not.
§ 590.01, subd. 4(b)(3) and (c) (Minnesota’s postconviction time bar exception): A petition may be heard if it relies on a new interpretation of law (by the U.S. Supreme Court or a Minnesota appellate court) that is retroactively applicable, and the petition is filed within two years of the decision announcing the new interpretation.
Knaffla bar: Typically prevents postconviction litigation of claims that were raised—or were known and could have been raised—on direct appeal. In this case, the Court held that when a petitioner files the first postconviction petition after a new, retroactive interpretation of law is announced, Knaffla does not impose an additional, independent barrier.

Conclusion

The Minnesota Supreme Court’s decision in Heard v. State establishes two significant principles:

Substantive mens rea rules in homicide retroactively apply: Coleman (requiring reckless disregard of human life) and Noor (excluding targeted conduct from third-degree depraved-mind murder) are new, substantive rules that apply retroactively to final convictions under Minn. Stat. § 609.195(a).
Access to postconviction review clarified: A petitioner invoking the § 590.01, subd. 4(b)(3) new-interpretation-of-law exception in the first postconviction petition filed within two years of the decision—and establishing retroactivity—need not independently overcome the Knaffla procedural bar.

By reversing and remanding, the Court directs lower courts to apply the refined mental-state standards of Coleman and Noor to the facts of each case to determine whether third-degree convictions can stand. The opinion meaningfully narrows third-degree depraved-mind murder to cases of generalized indifference and ensures that defendants with final convictions can obtain review when the law has substantively evolved in their favor.