Starting the Clock: Minnesota Supreme Court Clarifies Accrual and Strict Enforcement of the Two‑Year Postconviction Time Bar for “New Interpretation” and “Newly Discovered Evidence” Claims

Introduction

In Ricky Darnell Waiters v. State of Minnesota, 24 N.W.3d 265 (Minn. 2025), the Minnesota Supreme Court affirmed the summary denial of a fifth postconviction petition brought by a defendant convicted of first-degree felony murder and attempted first-degree felony murder. The case squarely addresses the operation of Minnesota’s statutory two-year time bar for postconviction relief—and, critically, when the two-year clock starts for two of the most frequently invoked exceptions: the “new interpretation of law” exception and the “newly discovered evidence” exception, Minn. Stat. § 590.01, subd. 4(b)(3) and (b)(2), respectively.

The petitioner, proceeding pro se, urged relief based on allegedly new legal interpretations (including State v. Noor and other recent decisions) and on scientific and media articles relating to bloodstain analysis. The district court originally denied his petition summarily within six days, prompting a previous remand from the Supreme Court for a reasoned order. On remand, after full briefing, the district court again denied relief, finding the petition both time-barred and procedurally barred. The Supreme Court affirmed on the time bar alone.

Key issues included:

Whether the petition—filed more than two years after the direct appeal concluded—was saved by exceptions for a new interpretation of law or newly discovered evidence.
When a claim “arises” for purposes of the two-year filing window under Minn. Stat. § 590.01, subd. 4(c).
Whether new legal theories (based on cases like Blevins and Dahir) can be raised for the first time on appeal from denial of postconviction relief.

Summary of the Opinion

The Minnesota Supreme Court affirmed the district court’s summary denial, holding that Waiters’s petition was untimely and that none of the asserted exceptions to the two‑year time bar applied:

New-interpretation-of-law exception (Minn. Stat. § 590.01, subd. 4(b)(3)): Although Noor announced a new interpretation of law, any claim relying on Noor had to be filed within two years of Noor’s issuance (September 15, 2021). Waiters filed on November 8, 2023; his claim was therefore time‑barred.
Newly discovered evidence exception (Minn. Stat. § 590.01, subd. 4(b)(2)): Claim accrual occurs when the petitioner knew or should have known of the evidence. The articles Waiters cited were published by June 2021, so any such claim arose no later than that date and had to be filed by June 2023. Filing in November 2023 was untimely.
New authorities raised for the first time on appeal (Blevins and Dahir): Forfeited, as issues not presented to the district court cannot be raised for the first time on appeal from denial of postconviction relief.

Because the time bar disposed of the case, the Court declined to reach the State’s additional arguments based on procedural bars (including the Knaffla rule and successive-petition dismissal).

Analysis

Precedents Cited and Their Influence

State v. Waiters (Waiters I), 929 N.W.2d 895 (Minn. 2019): The Court affirmed Waiters’s convictions on direct appeal, starting the routine postconviction timeline. Under § 590.01, subd. 4(a)(2), a petitioner has two years from the appellate disposition to seek postconviction relief unless a statutory exception applies.
Waiters v. State (Waiters II), 14 N.W.3d 279 (Minn. 2024): The Supreme Court remanded because the initial summary denial lacked an articulated basis. On remand, after the State responded and the district court issued a reasoned order, the Supreme Court had a complete record to review and affirmed on the time bar.
Wayne v. State, 866 N.W.2d 917 (Minn. 2015): Supports summary denial where a petition is time-barred. The Court applied Wayne to confirm that no evidentiary hearing is required if the files and records conclusively show no entitlement to relief due to the statute of limitations.
Martin v. State, 969 N.W.2d 361 (Minn. 2022): Establishes abuse-of-discretion review of summary denials.
Fox v. State, 913 N.W.2d 429 (Minn. 2018): Informs two principles: (1) facts are viewed in the light most favorable to the petitioner when reviewing summary denial, and (2) courts liberally construe pro se petitions. The Court did both here, but reminded that liberal construction does not override statutory time limits.
State v. Noor, 964 N.W.2d 424 (Minn. 2021) and Heard v. State, 22 N.W.3d 154 (Minn. 2025): Heard recognizes Noor as announcing a new rule for third-degree depraved-mind murder. In Waiters, the Court accepted Noor as a “new interpretation,” but held the claim untimely because it was not brought within two years of Noor, as § 590.01, subd. 4(c), requires.
Aili v. State, 963 N.W.2d 442 (Minn. 2021): Clarifies when a claim “arises” for the new-interpretation exception—on the date the appellate decision announces the interpretation. The Court applied Aili to fix Noor’s accrual date at September 15, 2021.
Evans v. State, 8 N.W.3d 642 (Minn. 2024): Defines accrual for newly discovered evidence as when the petitioner knew or should have known of the evidence. Waiters’s reliance on published articles meant his claim arose when those articles appeared (by June 2021), starting the two-year clock.
Riley v. State, 819 N.W.2d 162 (Minn. 2012): Sets out the five-part test for newly discovered evidence. Although the Court resolved Waiters’s claim on timeliness grounds, it noted that the petition did not explain how the articles would satisfy the demanding clear-and-convincing-innocence requirement, highlighting the stringent substantive hurdle.
Schleicher v. State, 718 N.W.2d 440 (Minn. 2006) and Powers v. State, 731 N.W.2d 499 (Minn. 2007): Emphasize that a party may not raise issues for the first time on appeal from denial of postconviction relief. Thus, arguments based on State v. Blevins, 10 N.W.3d 29 (Minn. 2024), and State v. Dahir, No. A22‑1287, 2023 WL 5198740 (Minn. App. Aug. 14, 2023), were forfeited because Waiters did not raise them below.
State v. Knaffla, 243 N.W.2d 737 (Minn. 1976) and Gilbert v. State, 2 N.W.3d 483 (Minn. 2024): The State argued Knaffla and statutory procedural bars; the Supreme Court declined to reach those issues given the dispositive time bar. Notably, the Court again flagged—but did not resolve—the ongoing question whether Knaffla and its exceptions survived the 2005 statutory amendments (see Heard and Sanders).

Legal Reasoning

The decision proceeds in three steps.

Baseline time limit. Under Minn. Stat. § 590.01, subd. 4(a)(2), petitioners whose convictions were affirmed on direct appeal must seek postconviction relief within two years of the appellate decision. Waiters’s direct appeal was decided on June 26, 2019; he filed the present petition on November 8, 2023—well outside the two-year window. Thus, the petition is untimely unless it qualifies for a statutory exception.
New interpretation of law exception—strict accrual and timing. For § 590.01, subd. 4(b)(3), the question is whether a new interpretation arose and whether the petition was brought within two years of that accrual under subd. 4(c). Aili fixes accrual at the date the appellate court announces the new interpretation. The Court accepted that Noor announced a new interpretation (as confirmed by Heard), but held that any Noor-based claim “arose” on September 15, 2021, and had to be filed by September 15, 2023. Waiters filed on November 8, 2023, making his claim untimely. The Court also noted, without deciding, that Waiters had not explained Noor’s retroactive applicability to his case—which involved felony murder, not third-degree depraved-mind murder.
Newly discovered evidence exception—publication date triggers accrual. For § 590.01, subd. 4(b)(2), Evans provides that accrual occurs when the petitioner knew or should have known of the evidence. The Court treated the cited scientific and media articles on bloodstain analysis as, at best, newly discovered evidence known or knowable upon publication (no later than June 2021). Thus, the two-year window to invoke this exception closed by June 2023; filing in November 2023 was untimely. The Court pointedly observed that Waiters had not explained how the articles could meet Riley’s clear-and-convincing-innocence standard.

Because timeliness was dispositive, the Court did not reach procedural bars under § 590.01, subd. 1, Knaffla, or successive-petition dismissal under § 590.04, subd. 3.

Impact and Practical Consequences

This opinion delivers several concrete takeaways for Minnesota postconviction practice:

Two-year clocks are rigorously enforced—know exactly when they start.
- New interpretation of law (subd. 4(b)(3)): The clock starts on the date the appellate court announces the new interpretation (Aili). For Noor-based challenges, the window closed on September 15, 2023. Petitions filed after that date are time-barred absent another exception.
- Newly discovered evidence (subd. 4(b)(2)): The clock starts when the petitioner knew or should have known of the evidence (Evans). For published articles, the publication date typically triggers accrual.
“Liberal construction” of pro se filings does not relax time limits. Courts will read pro se petitions generously but will still apply statutory deadlines strictly. Petitioners must articulate the exception and file within two years of accrual.
Raise all authorities and theories in the district court. New case-based arguments (e.g., Blevins, Dahir) not presented below are forfeited on appeal (Schleicher; Powers).
Scientific literature is not a silver bullet. Even if timely, papers criticizing forensic methods often face the Riley barrier: the evidence must be non-cumulative, non-impeaching, and must clearly and convincingly establish actual innocence. General critiques of methodology seldom meet that standard.
District courts may summarily deny time-barred petitions, but should explain why. After Waiters II, this case implicitly counsels district courts to provide a reasoned order when summarily denying relief, particularly on timeliness grounds, to facilitate appellate review and avoid unnecessary remands.
Knaffla’s status remains unresolved, but often unnecessary to reach. Consistent with recent cases (Heard; Sanders), the Court again avoided deciding whether Knaffla survived the 2005 amendments because the time bar sufficed. Expect continued reliance on § 590.01’s time limits as a threshold dispositive tool.

Complex Concepts Simplified

Postconviction relief: A statutory procedure allowing a convicted person to challenge a conviction or sentence after the direct appeal is over. Minnesota’s law imposes a two-year filing deadline with narrow exceptions.
Time bar (Minn. Stat. § 590.01, subd. 4): A filing deadline. If missed, the court will not consider the petition unless a specific statutory exception applies, and even then only if the exception is invoked within its own two-year window.
New interpretation of law exception (subd. 4(b)(3)): Applies when a Minnesota appellate court or the U.S. Supreme Court announces a new interpretation of constitutional or statutory law, and that interpretation is retroactively applicable. The claim “arises” on the date of the decision announcing the interpretation (Aili).
Newly discovered evidence exception (subd. 4(b)(2)): Applies when genuinely new evidence, undiscoverable with due diligence within the original time frame, emerges and, among other things, clearly and convincingly establishes the petitioner’s innocence (Riley). The claim “arises” when the petitioner knew or should have known of the evidence (Evans).
Retroactivity: For new-interpretation claims, petitioners must show that the new rule applies to their cases after they became final. Without retroactivity, the new rule cannot support postconviction relief.
Forfeiture of issues not raised below: Arguments not presented to the district court in the postconviction petition cannot be introduced for the first time on appeal from its denial.
Summary denial: A district court may deny a petition without a hearing if the files, records, and petition conclusively show no entitlement to relief—such as when the petition is time-barred.

Conclusion

Waiters v. State is a clear, practical roadmap for the timeliness of Minnesota postconviction petitions invoking the “new interpretation” and “newly discovered evidence” exceptions. The Court reaffirms that:

The two-year period for new-interpretation claims starts on the date the appellate court announces the new legal rule.
The two-year period for newly discovered evidence starts when the evidence was, or should have been, known to the petitioner—often the publication date for articles.
Pro se status does not soften these deadlines, and new legal authorities must be raised in the district court, not introduced for the first time on appeal.

By disposing of the case on the statutory time bar and declining to reach Knaffla issues, the Court underscores that § 590.01’s timing rules are a first-order, dispositive inquiry. For practitioners and petitioners alike, the message is unmistakable: identify the precise accrual date for any exception-based claim, file within two years of that date, and ensure that all legal theories and authorities are presented in the petition itself. Failure to do so will likely be fatal to postconviction relief.