Court affirms denial of postconviction relief to Campbell, convicted of first-degree murder, rejecting witness recantation, ineffective assistance, and Brady violation claims.
Outcome: Affirmed for appellee.
Campbell v. State
What happened
The facts of the case, in plain language.
Campbell presented only hearsay evidence that witness L.J. was recanting her trial testimony—a handwritten letter signed 'Business as Usual' (allegedly from L.J.'s uncle) and an affidavit from Campbell's counsel relaying what L.J.'s uncle said—rather than any direct sworn statement from L.J. herself.
Campbell's ineffective-assistance-of-counsel claim, alleging trial counsel failed to impeach certain witnesses, involved counsel's trial actions and strategy that were within Campbell's knowledge at the time of his direct appeal.
Witness I.R., whose testimony the State relied upon, had already been impeached at trial when he admitted under Campbell's counsel's questioning to lying to police multiple times and providing unreliable information because he was intoxicated.
Witness D.M., who was present in the car with Campbell and I.R., provided testimony corroborating I.R.'s key statements that Campbell possessed the mask, requested to be dropped off after they drove through the alley, and was picked up shortly after the shooting.
What the court decided
Joseph Haywood Campbell was convicted by a Ramsey County jury of first-degree premeditated murder of Naressa Turner committed for gang benefit, and sentenced to life imprisonment without possibility of release. After his direct appeal was affirmed, Campbell filed a postconviction petition claiming witness recantation, ineffective assistance of trial counsel, and Brady violation based on the State's alleged failure to disclose that witness I.R. received favorable sentencing treatment in exchange for testimony. The postconviction court denied the petition without an evidentiary hearing. The Minnesota Supreme Court affirmed, holding that Campbell presented only hearsay evidence of recantation lacking sufficient trustworthiness; the ineffective assistance claim was procedurally barred under Knaffla because it could have been raised on direct appeal; and even assuming the Brady allegation was true, the evidence was not material because I.R.'s credibility was already impeached at trial and corroborating testimony from witness D.M. existed.
- Hearsay evidence of a witness's purported willingness to recant—including unsworn letters relaying second-hand accounts and attorney affidavits reporting third-party statements—is insufficient to satisfy the first prong of the Larrison test, which requires the court to be reasonably well-satisfied that the material testimony was false. (*507)
- A postconviction court does not abuse its discretion by denying an evidentiary hearing on a witness-recantation claim when the proffered recantation evidence lacks sufficient indicia of trustworthiness to satisfy the first prong of the Larrison test. (*508)
- An ineffective-assistance-of-trial-counsel claim is procedurally barred under Knaffla when the defendant was fully aware of counsel's trial actions and strategy at the time of direct appeal and the claim is resolvable from the existing trial record without expansion. (*509)
- Suppressed evidence of favorable prosecutorial treatment given to a witness is not material under Brady when the witness's credibility was already substantially impeached at trial and a separate witness independently corroborated the key testimony. (*511)
How the court reached its decision
The court's reasoning, step by step.
Whether hearsay evidence of a witness's purported willingness to recant is sufficient to satisfy the first prong of the Larrison test for postconviction relief. Campbell offered an unsworn letter of unknown authorship signed 'Business as Usual' and a notarized attorney affidavit relaying what L.J.'s uncle said L.J. told him—both constituting multiple layers of hearsay—with no direct statement from L.J. identifying what she was recanting or why. Because the record contained no direct statement from L.J. and the submitted evidence was exclusively hearsay, Campbell failed to satisfy the first prong of Larrison; the postconviction court properly denied relief and the motion for an evidentiary hearing.
Whether Campbell's ineffective-assistance-of-trial-counsel claim is procedurally barred under Knaffla because it could have been raised on direct appeal. Campbell was fully aware of his trial counsel's methods and strategy—specifically the alleged failure to impeach certain witnesses—because those actions occurred at trial within his observation and are fully reflected in the trial record, unlike Leake v. State where record expansion was necessary. Because Campbell's IAC claim was within his knowledge at the time of direct appeal and required no record expansion, the claim was Knaffla-barred and summary denial was not an abuse of discretion.
Whether the State's undisclosed favorable sentencing treatment of witness I.R. constituted a material Brady violation entitling Campbell to postconviction relief. I.R. was already substantially impeached at trial when he admitted under cross-examination to lying to police multiple times and providing unreliable information due to marijuana intoxication; moreover, witness D.M., present in the same vehicle, independently corroborated each of I.R.'s material facts—the mask in Campbell's possession, Campbell's request to be dropped off before the murder, and Campbell's pickup shortly afterward. Because I.R.'s credibility was already undermined and D.M. corroborated his key testimony, evidence of an undisclosed deal did not create a reasonable probability of a different result; the evidence was not material and Campbell suffered no Brady prejudice.
Key quotes from the opinion
Notable passages from the opinion, in the court's own words.
Cases the court relied on
Earlier decisions the court cited as authority for its ruling.
Full opinion
The complete text of the court's opinion as published.
Opinion of the Court
*505In this case we are asked to determine whether the postconviction court erred by denying appellant Joseph Haywood Campbell's petition for postconviction relief without an evidentiary hearing. Because we conclude that the postconviction court did not err, we affirm.
FACTS
A Ramsey County jury found Campbell guilty of the first-degree premeditated murder of Naressa Turner, committed for the benefit of a gang, in violation of
Campbell, who was an associate of the Eastside Boys gang, visited the home of witness L.J. on the day of Turner's murder. According to L.J.'s trial testimony, Campbell had a phone conversation while he was at her home. During that conversation, Campbell learned that Turner was back in the area after having moved away. L.J. testified that Campbell said "f**k her" and that Turner was an "OP," which means from a different gang or from the other side of the neighborhood. L.J. also testified that Campbell had a gun in his possession at the time.
After he left L.J.'s home, Campbell rode with I.R., D.M., and C.B. to a Super USA gas station in St. Paul. Campbell was recorded by the gas station surveillance camera wearing a black North Face jacket and a Halloween mask. D.M. testified that Campbell still had the mask when he returned to the car after leaving the gas station.
Turner was at the same Super USA gas station. She was there with two companions to purchase marijuana. Turner and her companions met L.H. at the station and followed him out of the station. L.H. drove a Chevrolet Malibu, and Turner followed *506in a Cadillac Escalade. Both vehicles drove through an alley and parked.
I.R. testified that he, Campbell, D.M., and C.B. then drove through the same alley. After passing by the Escalade, Campbell and C.B. asked to be let out of the car. I.R. also testified that, as they passed the Escalade, he heard someone in the back seat say they could not believe Turner was on the East Side.
Minutes after Campbell was let out of the car, a masked person approached the Escalade and fired nine shots from a handgun. Turner sustained multiple gunshot wounds, which resulted in her death. Approximately 15 minutes later, I.R. spotted Campbell on the street and gave him a ride. I.R. noted that Campbell was no longer wearing the black North Face jacket. Campbell subsequently asked to be dropped off, and he then disappeared from St. Paul for 6 weeks.
The jury found Campbell guilty of first-degree premeditated murder for the benefit of a gang. Campbell ,
Following his direct appeal, Campbell filed a petition for postconviction relief. In his petition, Campbell alleged that L.J. recanted her trial testimony. He also alleged that his trial counsel was ineffective and that the State did not disclose exculpatory information. The postconviction court denied the petition without an evidentiary hearing.
The postconviction court rejected the witness-recantation claim, determining that the test from Larrison v. United States ,
ANALYSIS
On appeal, Campbell argues that the postconviction court erred in concluding that the allegations in his petition failed to meet the standard set out in Larrison for witness-recantation claims. Campbell also contends that the postconviction court erred in concluding that Knaffla bars his ineffective-assistance-of-counsel claim and his claim that the State failed to turn over exculpatory evidence as required under Brady v. Maryland ,
I.
We turn first to Campbell's witness-recantation claim. Campbell argues that L.J.
*507recanted her trial testimony and that he therefore is entitled to a new trial or, at a minimum, an evidentiary hearing. The postconviction court concluded that Campbell's claim did not satisfy the test from Larrison . The postconviction court therefore denied Campbell's petition and his motion for an evidentiary hearing.
A.
The Larrison test requires that: (1) the court is reasonably well-satisfied that the testimony given by a material witness is false; (2) without that testimony the jury might have reached a different conclusion; and (3) the party seeking a new trial was taken by surprise when the false testimony was given and was unable to meet it or did not know of its falsity until after trial. Williams v. State ,
The postconviction court rejected Campbell's witness-recantation claim, concluding that it failed under all three prongs of the Larrison test. We need not decide whether Campbell's claim fails under the second or third prong, because we conclude it fails to meet the first prong. See Martin v. State ,
On the first prong, the postconviction court found that Campbell's allegation that L.J.'s testimony "was false is based on a letter ... with no statements from the witness herself." The record supports that finding. The letter Campbell offered is handwritten and signed by "Business as Usual." Campbell argues that the letter is from L.J.'s uncle, and that it provides evidence that L.J. is recanting her trial testimony. But the letter is not a sworn statement, and the record does not establish who wrote it. Moreover, the letter does not identify L.J. as the recanting witness, explain why the witness has chosen to recant, or even describe what part of the testimony is being recanted. Finally, the letter contains hearsay within hearsay because it is an out of court statement that a witness (allegedly L.J.) told the letter's author that the witness was recanting her testimony.
In addition to the letter, Campbell offered an affidavit from his counsel. The affidavit asserts that L.J.'s uncle told Campbell that L.J. "falsely testified" against Campbell at his trial and that she "is willing to recant." The affidavit also states that Campbell's counsel went to L.J.'s home and attempted to interview her about Campbell's trial, but L.J. was not available. Although the affidavit is notarized, it contains multiple layers of hearsay. Specifically, the affidavit reports that L.J.'s uncle told Campbell that L.J. told her uncle that her trial testimony was false and that she was willing to testify to that falsity.
As the postconviction court found, the record contains no direct statements from L.J. that she is actually recanting any of her trial testimony. At best, the record contains hearsay evidence that she is "willing" to do so. But we have "never held" that hearsay evidence is sufficient to warrant a new trial under the first prong of Larrison . McKenzie v. State ,
Based on this analysis, we hold that the postconviction court properly determined that Campbell did not satisfy the first prong of Larrison and was therefore not entitled to a new trial on his witness-recantation claim.
*508B.
Campbell argues that even if he is not entitled to a new trial, he is at least entitled to an evidentiary hearing on his recantation claim. And he argues that the postconviction court erred in applying the Larrison test to his request for an evidentiary hearing. Specifically, Campbell argues that the Larrison test is applied when deciding whether to grant a new trial, not whether to hold a postconviction evidentiary hearing. Campbell asserts that rather than the Larrison test, the correct standard for granting an evidentiary hearing is whether the newly discovered evidence that L.J.'s testimony is something other than what she testified to at trial might cause the jury to reach a different conclusion. The State contends that although a different threshold may apply when awarding an evidentiary hearing, the Larrison test is still applicable to Campbell's witness-recantation claim. The State further asserts that because the postconviction court concluded that Campbell failed to satisfy the first prong of Larrison , it did not abuse its discretion in denying Campbell's motion for an evidentiary hearing.
The State is correct that the Larrison test is applicable when addressing whether a witness-recantation claim requires an evidentiary hearing. In applying the Larrison test, we must first assume the truth of the allegations in the petition. Ortega ,
In this case, the postconviction court did not abuse its discretion in concluding that Campbell was not entitled to an evidentiary hearing on his witness-recantation claim. The postconviction court determined that the facts alleged in the petition did not satisfy the first prong of Larrison. Campbell asserts, and we agree, that any doubts as to whether to grant an evidentiary hearing should be resolved in his favor. Ferguson v. State ,
That standard is plainly not met here. See
Because Campbell has not proffered evidence with sufficient indicia of trustworthiness that, if proven true, would satisfy the first prong of the Larrison test, we hold that the postconviction court did not abuse its discretion by summarily denying Campbell's witness-recantation claim without an evidentiary hearing.
II.
We turn next to Campbell's claim asserting ineffective assistance of trial counsel. Campbell asserts that his trial counsel was constitutionally ineffective because counsel did not impeach certain witnesses during trial. The postconviction court concluded that this claim is Knaffla -barred because it was known or should have been known at the time of his direct appeal. The State agrees with the postconviction court that Campbell's claim is Knaffla -barred.
All claims that were known or should have been known at the time of the direct appeal, but not raised on appeal, are procedurally barred from being raised in a later postconviction petition. Davis v. State ,
During the time of his direct appeal, Campbell was aware of the methods and strategy his counsel used during trial. Therefore, his claim could have been brought on direct appeal. See Sanchez-Diaz v. State ,
In urging us to reach a different result, Campbell contends that his case is similar to Leake v. State ,
III.
Finally, we turn to Campbell's Brady -violation claim. Campbell alleges that the State violated Brady when it did not disclose that the State treated I.R. more favorably at sentencing on an illegal-possession-of-firearms charge because of his testimony against Campbell.
We need not decide whether Campbell could have raised the Brady claim on direct appeal. Even assuming the truth of the allegations Campbell makes, Campbell is not entitled to postconviction relief.
Under Brady , suppression by the State of material evidence favorable to the defendant violates the constitutional guarantee of due process. Brady v. Maryland ,
Assuming Campbell's allegations are true, the first two prongs are met. His claim then hinges on the third prong of the *511Brady analysis, whether the evidence was material. Walen ,
Based on our review of the record, we conclude that evidence of a deal between I.R. and the State was not material in this case for two reasons. First, I.R.'s credibility was successfully impeached by the defense at trial. In response to questions asked by Campbell's counsel, I.R. admitted to lying to the police on multiple occasions during the investigation and providing unreliable information because he was high on marijuana when the events took place. If a witness has already been impeached, further impeachment would be unlikely to have an effect on the outcome of the case. See State v. Miller ,
Second, most of I.R.'s testimony was also given by D.M., who was in the car with I.R. and Campbell. I.R. provided testimony that placed the mask that multiple witnesses recognized as the mask worn by the shooter in Campbell's possession. I.R. also testified that when he was driving his car through the alley where Turner was, he heard someone in the back seat say they could not believe Turner was on the East Side. Additionally, I.R. testified that Campbell exited his car immediately before the murder of Turner and that when he picked Campbell up 15 minutes later, Campbell was no longer wearing the black North Face jacket he had worn earlier. Much of D.M.'s testimony echoed these statements, including testimony that Campbell was in possession of the mask at the gas station and in the car after the shooting, that Campbell requested to be dropped off after the car they were in drove through the alley, and that he and I.R. saw Campbell a short while after the shooting and picked him up.
Because I.R.'s credibility was already impeached and most of the relevant parts of I.R.'s testimony were also given by D.M., we conclude that additional impeachment based on evidence of a deal between I.R. and the State was not material and Campbell was not prejudiced. We therefore hold that the postconviction court did not err in summarily dismissing Campbell's Brady - violation claim.
CONCLUSION
For the foregoing reasons, we affirm the decision of the postconviction court.
Affirmed.
THISSEN, J., not having been a member of the court at the time of submission, took no part in the consideration or decision of this case.
Campbell ,
Larrison has been overruled, see United States v. Mitrione ,
There are two exceptions to the Knaffla bar: (1) if a claim is so novel that the legal basis was unavailable on direct appeal, or (2) if fairness requires review and the petitioner did not deliberately and inexcusably fail to raise the claim on direct appeal. McKenzie v. State ,
Under Brady , a plea bargain in exchange for testimony is exculpatory evidence because it can be used to impeach a witness. Giglio v. United States ,
In addition, Campbell asserts that the prosecutor's failure to correct I.R.'s false testimony that he did not receive consideration was an error. Campbell, however, fails to cite any legal authority for this claim and provides no other factual or evidentiary support for it. A claim of error "based on mere assertion and not supported by any argument or authorities in appellant's brief is waived and will not be considered on appeal unless prejudicial error is obvious on mere inspection." State v. Andersen ,
Continue your research
- Minnesota postconviction cases applying the indicia-of-trustworthiness standard to recantation evidence after Campbell
- Brady materiality cases where the witness was already impeached at trial or corroborating testimony existed
- Secondary sources on the Knaffla bar and its exceptions for ineffective-assistance-of-counsel claims requiring record development
Case-law data current through December 31, 2025. Source: CourtListener bulk data.