Courts Are Not Agencies: Loper Bright Does Not Trigger Minnesota’s Postconviction “New Interpretation of Law” Exception and the Two-Year Time Bar Remains Strict

Introduction

In Nantambu Noah Kambon v. State of Minnesota, 23 N.W.3d 576 (Minn. 2025), the Minnesota Supreme Court reaffirmed the rigor of the State’s postconviction time limits and clarified the narrow scope of the “new interpretation of law” exception in Minn. Stat. § 590.01, subd. 4(b)(3). Nearly three decades after his convictions for the 1992 shooting death of Minneapolis Police Officer Jerry Haaf, Kambon (formerly known as Shannon Bowles) filed a second postconviction petition seeking a new trial based on alleged errors surrounding jury deliberations and juror misconduct, as well as a novel timeliness theory premised on the United States Supreme Court’s 2024 decision in Loper Bright Enterprises v. Raimondo, which overruled the Chevron deference doctrine.

The central issues were:

Whether Kambon’s 2024 petition was time-barred by Minnesota’s two-year postconviction limitation, given that his conviction became final in the mid-1990s.
Whether the “new interpretation of law” exception under § 590.01, subd. 4(b)(3), saved his petition—either via older Minnesota cases such as State v. Kelley (1994) or via Loper Bright’s repudiation of Chevron.
Whether the district court erred by denying an evidentiary hearing and by not revisiting the prior handling of alleged juror coercion and a requested Schwartz hearing.

The Court, per Justice Thissen, affirmed the summary denial of postconviction relief.

Summary of the Opinion

The Court held:

Under Minn. Stat. § 590.01, subd. 4(a), postconviction petitions must be filed within two years of the conviction becoming final or of the appellate disposition on direct appeal. For convictions final before August 1, 2005, the deadline was August 1, 2007. Kambon’s 2024 petition was plainly untimely.
The “new interpretation of law” exception in § 590.01, subd. 4(b)(3), read together with § 590.01, subd. 4(c), did not apply. Even assuming a new, retroactive rule, a petitioner must file within two years of the date the claim arises. Reliance on 1994 decisions (Kelley and Harris) was decades too late, and the 2024 Loper Bright decision does not apply to judicial precedent and therefore does not make Kambon’s claims timely.
Courts are not administrative agencies; Chevron deference never governed the level of deference courts owe to their own prior decisions or to district court determinations. Accordingly, overruling Chevron in Loper Bright has no bearing on Minnesota courts’ treatment of their precedents or on § 590.01’s new-law exception.
Several of Kambon’s arguments were forfeited (not raised in the district court or not briefed on appeal) or were subject to procedural bars, including the successive-petition bar and the Knaffla rule.
The denial of an evidentiary hearing was proper because the petition conclusively showed he was not entitled to relief under the time-bar and controlling procedural doctrines.

Analysis

Precedents Cited and Their Role

Wayne v. State, 912 N.W.2d 633 (Minn. 2018): The Court relied on Wayne to calculate the operative deadline for pre-2005 convictions. Those convictions had to be challenged by August 1, 2007. This set the temporal backdrop against which the petition’s untimeliness was obvious.
Minn. Stat. § 590.01, subds. 4(a), 4(b)(3), 4(c) (2024): These subdivisions provide the two-year limitation period; the exception for “new interpretations of federal or state law” that are retroactively applicable; and the two-year-from-arising clock for such exception claims. The Court emphasized the interlock between subd. 4(b)(3) and subd. 4(c): even when a new, retroactive rule exists, the petition must be filed within two years of that new rule.
State v. Kelley, 517 N.W.2d 905 (Minn. 1994) and State v. Harris, 521 N.W.2d 348 (Minn. 1994): Kambon invoked these as “new interpretations.” The Court rejected that argument because any new-law claim based on 1994 decisions had to be brought within two years of when it “arose” (§ 590.01, subd. 4(c)). Filing nearly 30 years later is untimely.
Loper Bright Enters. v. Raimondo, 603 U.S. 369 (2024) and Chevron U.S.A., Inc. v. NRDC, 467 U.S. 837 (1984): The Minnesota Supreme Court rejected the premise that Loper Bright’s abolition of Chevron deference affects how Minnesota appellate courts treat their own precedents or district court rulings. Chevron addressed deference to administrative agencies’ statutory interpretations, not stare decisis or judicial hierarchies. The Court added that Minnesota courts never explicitly adopted Chevron as a principle of state law.
Schwartz v. Minneapolis Suburban Bus Co., 104 N.W.2d 301 (Minn. 1960) and State v. Jackson, 977 N.W.2d 169 (Minn. 2022): These establish and describe the procedure for investigating alleged juror misconduct via a Schwartz hearing—central to Kambon’s earlier litigation about Juror #4 and the jury’s deliberations.
State v. Bowles (Bowles I), 530 N.W.2d 521 (Minn. 1995); State v. Bowles (Bowles II), 533 N.W.2d 617 (Minn. 1995) (order); Kambon v. State (Bowles III), 583 N.W.2d 748 (Minn. 1998): The Court revisited its prior handling of the case. In Bowles I, it remanded for further record development on the juror-misconduct concerns surrounding Juror #4 and the judge-jury communications, citing Kelley’s guidance on jury communications. In Bowles II, it affirmed after receiving the trial judge’s detailed memorandum. In Bowles III, it applied the Knaffla bar to reject postconviction claims that could have been raised on direct appeal.
State v. Knaffla, 243 N.W.2d 737 (Minn. 1976): The Knaffla rule blocks postconviction consideration of issues raised—or known and not raised—on direct appeal. Bowles III applied Knaffla to Kambon; that bar remained relevant context for the present petition.
Minn. Stat. § 590.04, subds. 1, 3 (2024); El-Shabazz v. State, 984 N.W.2d 569 (Minn. 2023): Subd. 1 allows summary denial without an evidentiary hearing if the record conclusively shows no entitlement to relief; El-Shabazz articulates that standard. Subd. 3 authorizes summary denial of successive petitions raising issues previously decided.
Onyelobi v. State, 932 N.W.2d 272 (Minn. 2019): Cited in support of the successive-petition bar for issues already decided in the same case.
Davis v. State, 15 N.W.3d 635 (Minn. 2025); Reed v. State, 793 N.W.2d 725 (Minn. 2010): These cases provide the abuse-of-discretion standard for review of summary postconviction denials and define when a district court’s ruling rests on an erroneous view of the law or clearly erroneous fact findings.
Schleicher v. State, 718 N.W.2d 440 (Minn. 2006) and Pearson v. State, 946 N.W.2d 877 (Minn. 2020): Schleicher confirms forfeiture of issues not raised in the postconviction petition; Pearson notes the Court’s discretion to address issues in the interest of judicial economy even if imperfectly preserved—used here to reject the Loper Bright theory on the merits.
State v. Robinette, 964 N.W.2d 143 (Minn. 2021): Issues not briefed on appeal are forfeited, which removed certain claims from consideration.
Minn. Const. art. III, § 1: Minnesota’s separation of powers provision undergirded the Court’s statement that courts are not administrative agencies, undercutting any attempt to import administrative deference concepts into judicial precedent.
Davis v. United States, 564 U.S. 229 (2011) and United States v. Leon, 468 U.S. 897 (1984): Cited to reject Kambon’s alternative analogy: the Fourth Amendment’s good-faith exception has no application to whether Minnesota courts should “defer” to their prior decisions or to timeliness under § 590.01.

Legal Reasoning

The Court’s reasoning proceeds in layered steps:

Time bar under § 590.01, subd. 4(a), and Wayne: Because Kambon’s conviction became final before August 1, 2005, any postconviction petition had to be filed by August 1, 2007. A 2024 filing is untimely on its face.
“New interpretation of law” exception is narrow and time-bound (§ 590.01, subds. 4(b)(3), 4(c)): The exception requires (a) a new interpretation of federal or state law, (b) retroactive applicability, and (c) filing “within two years of the date the claim arises.” The Court emphasized subd. 4(c)—even if one assumes a qualifying new rule, a petitioner must act within two years of that rule’s issuance. Thus, reliance on 1994 decisions is untimely. Reliance on Loper Bright fails for a different reason: it is not a new law that applies to Kambon’s claims.
Loper Bright/Chevron does not apply to courts or Minnesota postconviction practice: Loper Bright overruled a doctrine that governed how courts review agency interpretations of statutes. It did not change any rule about how appellate courts treat their own precedents or district court rulings. Minnesota courts never explicitly adopted Chevron as a matter of Minnesota law, and, in any event, courts are not agencies. Accordingly, Loper Bright is not a “new interpretation of law” that “applies” to Kambon’s case within the meaning of § 590.01, subd. 4(b)(3).
Forfeiture and successive-petition bars supplement the time bar: The Loper Bright theory was not raised in the district court and is forfeited (Schleicher), though the Court rejected it on the merits in the interest of judicial economy (Pearson). Several other arguments had been previously litigated and could be summarily denied under § 590.04, subd. 3 (Onyelobi). And claims known at the time of direct appeal remained barred by Knaffla, consistent with the Court’s earlier disposition in Bowles III.
No evidentiary hearing was required: Under § 590.04, subd. 1, and El-Shabazz, a hearing is unnecessary when the record conclusively shows a petitioner is not entitled to relief. The statutory time bar, combined with the inapplicability of the new-law exception and the procedural bars, made the hearing unnecessary.

Impact

This opinion has significant implications for Minnesota postconviction practice:

Strict enforcement of the two-year limit: The Court underscores that § 590.01’s deadlines are hard-edged. For pre-2005 convictions, August 1, 2007, was the last day to file unless a narrow statutory exception applies, and even then, the exception has its own two-year clock tied to the new ruling.
Tightening the “new interpretation” exception: Petitioners cannot use broadly consequential federal decisions to reopen old cases unless the decision is a new, retroactive interpretation that actually bears on their claims and they file within two years of that decision. Not every high-profile ruling qualifies; applicability is the key.
Chevron and Loper Bright are out of place in this context: The Court decisively forecloses attempts to import administrative-law deference doctrines into questions of judicial precedent or postconviction timeliness. Future litigants should not expect Loper Bright (or similar federal administrative-law developments) to satisfy § 590.01, subd. 4(b)(3).
Reaffirmation of procedural bars: The opinion reinforces that Knaffla, forfeiture for failure to raise issues in the district court or brief them on appeal, and the successive-petition bar remain robust screening tools in postconviction litigation.
Practical signaling to courts and counsel: District courts can confidently deny stale petitions on the papers when time-bar and procedural doctrines conclusively bar relief. Petitioners must tie any “new law” exception to a retroactive rule directly governing their claim and file within the exception’s two-year window.

Complex Concepts Simplified

Two-year time bar (Minn. Stat. § 590.01, subd. 4(a)): Most postconviction petitions must be filed within two years of the conviction’s finality or the appellate decision on direct appeal. For convictions final before August 1, 2005, the drop-dead date was August 1, 2007.
“New interpretation of law” exception (§ 590.01, subd. 4(b)(3) and subd. 4(c)): If a court later issues a new legal interpretation that applies retroactively to your case, you may file a petition based on that new rule—but you must do so within two years of the date that new-law claim “arises” (usually the date of the new decision).
Knaffla bar: You cannot use a postconviction petition to re-raise issues you brought on direct appeal or to raise issues you knew about but did not bring on direct appeal.
Successive-petition bar (§ 590.04, subd. 3): If an appellate court has already decided an issue in the same case, a district court can summarily deny a new petition that tries to relitigate that issue.
Schwartz hearing: A court-supervised process for investigating alleged juror misconduct by questioning jurors in the presence of counsel. It is not automatic; it is used when there are sufficient allegations of misconduct.
Chevron deference vs. judicial precedent: Chevron was a federal doctrine instructing courts to defer to reasonable agency interpretations of ambiguous statutes. It never governed how courts treat their own prior decisions (stare decisis) or trial court rulings. Loper Bright eliminated Chevron for agency deference; it does not diminish the authority of court precedents or change postconviction time rules.

Conclusion

The Minnesota Supreme Court’s decision in Kambon v. State reinforces a clear message: postconviction relief is hemmed in by strict statutory timelines and well-settled procedural bars. The “new interpretation of law” exception is not a catch-all to revive decades-old claims; it requires a genuinely applicable, retroactive legal development, and it carries its own two-year deadline. By explicitly rejecting the notion that Loper Bright’s overruling of Chevron has any bearing on judicial deference to precedent—or on Minnesota’s postconviction timeliness rules—the Court shuts the door on a creative but doctrinally unfounded route around § 590.01’s time bar.

For practitioners and petitioners, the takeaways are practical and firm: file timely, preserve issues at each stage, and tether any “new law” argument to a decision that both applies retroactively and specifically affects the claim at issue—then act within two years of that decision. Courts remain vigilant in enforcing these constraints, and this opinion offers a crisp roadmap for applying them.