Supreme Court Digest: May 13, 2026

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Criminal

Felony Murder

Aiding & Abetting

Appellant appealed from the district court’s denial of relief under the Act of May 19, 2023, ch. 52, art. 4, § 24, 2023 Minn. Laws 810, 864–68, a session law that established a pathway to challenge certain convictions for felony murder that were based upon an aiding-and-abetting theory of liability. In 2004, a jury found appellant guilty of two counts of first-degree felony murder and one count of attempted first-degree felony murder, each under an aiding-and-abetting theory of criminal liability, and his conviction was affirmed on direct appeal. Twenty years after his trial, in 2024, appellant sought to vacate his first-degree felony murder convictions under the Act. After reviewing appellant’s preliminary application, the district court allowed him to file a petition to vacate his convictions and scheduled an evidentiary hearing. At the evidentiary hearing, appellant’s attorney told the district court that appellant would not offer any live witness testimony, and that the district court should decide the case based on trial transcripts and other documentary records. After weighing the evidence presented at the evidentiary hearing, the district court denied appellant’s petition to vacate. The district court determined that appellant failed to prove, by a preponderance of the evidence, that he did not act with the intent to kill the three victims of the shooting.

The Supreme Court held that (1) they review an appeal from a district court’s denial of a petition to vacate under the Act of May 19, 2023, ch. 52, art. 4, § 24, 2023 Minn. Laws 810, 864–68, for an abuse of discretion; (2) the district court did not abuse its discretion in denying the appellant’s petition to vacate his first-degree felony murder convictions under an aiding-and-abetting theory of liability; (3) upon holding an evidentiary hearing under the Act, a district court does not err by weighing the evidence presented by the parties to reach its determination; and (4) following an evidentiary hearing, a district court reviewing a petition to vacate under the Act is not required to resolve any uncertainties in favor of the petitioner. Affirmed.

A25-0102 Green v. State (Ramsey County)