If you must hide a body, do not decorate it with Christmas lights!

2016-M-343            Brian Keith Hooper, Appellant, vs. State of Minnesota, Respondent.

BACKGROUND:  Here, the Supreme Court rejected Hooper’s fourth post-conviction appeal, both because this appeal violated the two-year deadline for such appeals and because many of the claims brought here were barred by the Knaffla doctrine which bars subsequent appellate claims that had already been raised on an earlier appeal or should have been known and brought in an earlier appeal.

Hooper was a crack addict who had been implicated in earlier crimes, including murder.

In April, 1998, Hooper went to the Minneapolis apartment of Ann Prazniak to smoke crack cocaine.  He stabbed Prazniak to death, covered her head and wrists in masking tape, wrapped her body in a mattress pad and trash bags, crammed her body in a box, decorated the box in Christmas lights, stashed the box in her bedroom closet, and left matching strips of the masking tape on the floor with his fingerprints.  His fingerprints were also found on the Christmas lights.

At trial, four witnesses testified that Hooper had confessed the murder to them.  One witness testified that Hooper had brought her into the apartment to help hide the body and clean the apartment. 

The jury convicted Hooper of three counts of first-degree murder, and the district court sentenced him to life imprisonment without the possibility of parole.

In 2000, the Supreme Court rejected Hooper’s first post-conviction appeal, holding that there was sufficient evidence to sustain his convictions.

In 2004, the Supreme Court rejected Hooper’s second post-conviction appeal, holding that Hooper had not provided sufficient evidence that two of the witnesses may have recanted their testimony after the trial.

In 2013, the Supreme Court rejected Hooper’s third post-conviction appeal, holding that Hooper had already litigated the alleged recantations of the two witnesses and that the post-conviction court had properly held that Hooper’s new allegation about a recantation by a third witness was not credible.

In 2014, Hooper filed this, his fourth post-conviction appeal.  The post-conviction court denied this appeal, both because it violated the two-year deadline for such appeals and because many of the claims were barred by the Knaffla doctrine.

HELD:  The Supreme Court held that the post-conviction court did not abuse its discretion by summarily denying appellant's fourth petition for post-conviction relief because the petition was untimely under the 2-year post-conviction statute of limitations, and appellant's previously raised claims are procedurally barred.

Anderson (Gildea, Stras, Hudson, Chutich, and McKeig)

Took No Part:  Lillehaug.

               [CRIME] [MURDER] [PREMEDITATED] [FIRST-DEGREE]

Date: December 14, 2016