Setting the Standard: Abuse-of-Discretion Review for Preliminary Denials Under Minnesota’s 2023 Aiding-and-Abetting Felony-Murder Relief Act

Case: State of Minnesota v. Diamond Lee Jamal Griffin

Citation: 24 N.W.3d 247 (Minn. 2025)

Court: Supreme Court of Minnesota

Date: July 30, 2025

Author: Moore, III, J.

Introduction

This decision marks the Minnesota Supreme Court’s first merits opinion interpreting the preliminary review process created by the 2023 session law offering relief to certain individuals convicted of felony murder under an aiding-and-abetting theory. The court resolves two foundational issues: (1) what standard of appellate review applies to a district court’s preliminary denial of relief under the Act of May 19, 2023, ch. 52, art. 4, § 24, 2023 Minn. Laws 810, 864–68 (the “Act”); and (2) whether the district court abused its discretion in denying appellant Diamond Lee Jamal Griffin’s preliminary application. The case arises from Griffin’s 2014 conviction for first-degree intentional felony murder under Minn. Stat. § 609.185(a)(3) (2012), for the shooting death of Francisco Benitez-Hernandez.

The parties were the State of Minnesota (respondent) and Griffin (appellant), who proceeded pro se on appeal. The key legal question at this early procedural juncture concerns whether the application and judicial records show a “reasonable probability” that Griffin neither caused the victim’s death nor intentionally aided another to cause death—threshold criteria the Act requires for applicants convicted under an aiding-and-abetting theory. Because the State did not contest eligibility, the court assumed (without deciding) that Griffin could seek relief. Ultimately, the Supreme Court affirms the district court’s denial of the preliminary application.

Summary of the Opinion

  • Standard of Review Established: The court holds that an abuse-of-discretion standard governs appellate review of a district court’s denial of a preliminary application under the Act. This flows from the Act’s text—requiring a determination “in the discretion of” the judge—and from the court’s prior jurisdictional ruling treating these appeals as akin to postconviction matters under Minn. Stat. ch. 590.
  • Application of the Standard: The court concludes the district court did not abuse its discretion in denying Griffin’s application. Considering the application, its supporting materials, and relevant judicial records, there is no reasonable probability that Griffin “did not cause the death” of a human being. Earlier appellate decisions (especially State v. Griffin (Griffin I), 887 N.W.2d 257 (Minn. 2016)) upheld findings that Griffin himself shot and killed the victim with intent to kill.
  • Scope of Record and Errors: The Act authorizes district courts to consult “relevant records in the possession of the judicial branch,” including prior appellate decisions. Although the district court incorrectly stated that the jury determined Griffin was the shooter (the hybrid instructions allowed conviction on either a principal or accomplice theory and the verdict did not specify), that misstatement did not render the decision an abuse of discretion given the full record and the Supreme Court’s prior factual conclusions.
  • Issues Reserved: The court does not define the Act’s “reasonable probability” standard or decide whether a defendant convicted under hybrid instructions is “convicted … under the theory of liability for crimes of another” for eligibility purposes. Those issues remain for future cases.

Analysis

Precedents Cited and Their Influence

  • State v. Griffin (Griffin I), 887 N.W.2d 257 (Minn. 2016): On direct appeal, the court affirmed Griffin’s conviction, concluding that “the circumstances proved support a reasonable inference that Griffin shot Benitez‑Hernandez with an intent to kill him” and were inconsistent with any rational hypothesis other than guilt. Griffin I’s factual narrative—Griffin aimed, struck the victim with the gun, then redirected and fired into the victim’s chest—anchors the present decision’s conclusion that Griffin “caused the death.” The prior holding also undercuts Griffin’s current argument that the shooter’s identity remained genuinely unclear.

  • Griffin v. State (Griffin II), 941 N.W.2d 404 (Minn. 2020) and Griffin v. State (Griffin III), 961 N.W.2d 773 (Minn. 2021): These decisions affirmed dismissals of Griffin’s subsequent postconviction petitions as time-barred under Minn. Stat. § 590.01, subd. 4(a), and invoked the Knaffla bar. They reinforce the posture that much of the factual record is settled and that collateral attacks must fit within tight statutory confines—an approach the court analogizes to when choosing the abuse-of-discretion standard here.

  • State v. Griffin (Griffin IV), 20 N.W.3d 57 (Minn. 2025) (order): While not the merits decision, this earlier order established appellate jurisdiction and the procedural channel. The court relied on Minn. R. Crim. P. 29.02, subd. 1(b) (appeals from final postconviction orders) and held that chapter 590’s remedy “is broad enough to encompass” appeals from preliminary denials under the Act. Today’s opinion leverages that postconviction analogy to fix the abuse-of-discretion standard.

  • State v. Ezeka, 946 N.W.2d 393 (Minn. 2020): The court notes that “the era of hybrid instructions has ended,” underscoring that Griffin’s trial predated modern clarity requiring the jury to identify the theory of liability. This historical note matters because the Act’s eligibility turns on whether a person was convicted under an aiding-and-abetting theory; hybrid verdicts blur that line and present open questions for future litigation.

  • Riley v. State, 792 N.W.2d 831 (Minn. 2011): Defines abuse of discretion (decision based on an erroneous view of law or against logic and facts), and clarifies the split between clear-error review of factual findings and de novo review of legal conclusions. The court applies this framework to the Act’s preliminary denial.

  • State v. Martens, 18 N.W.3d 752 (Minn. 2025): Confirms de novo review for pure legal questions, which the court uses to select the correct standard of review for these new Act appeals.

  • State v. Hannuksela, 452 N.W.2d 668, 673 n.7 (Minn. 1990): The court may address issues necessary to resolve a case “in accordance with law,” even if not fully briefed by the parties. Here, the court flags—but does not decide—eligibility under the Act given the hybrid instruction backdrop.

  • Other citations for context: State v. Spreigl, 139 N.W.2d 167 (Minn. 1965) (other-acts evidence); Brady v. Maryland, 373 U.S. 83 (1963) (due process disclosure); State v. Knaffla, 243 N.W.2d 737 (Minn. 1976) (postconviction procedural bar). The court also notes unpublished court of appeals decisions applying an abuse-of-discretion framework to Act denials, e.g., Raisch v. State, 2024 WL 3564548 (Minn. App. July 29, 2024), and Dirk v. State, 2025 WL 5036718 (Minn. App. Feb. 26, 2025), as consistent with today’s holding.

Legal Reasoning

1. Selecting the appellate standard of review. The Act directs a reviewing judge to determine, “in the discretion of that judge,” whether there is a reasonable probability the applicant is entitled to relief. Reading this text together with Griffin IV’s jurisdictional rubric treating these proceedings as postconviction analogs, the court adopts the abuse-of-discretion standard used for postconviction appeals. This choice aligns the new statutory mechanism with established norms: deference to district courts at early gatekeeping stages, clear-error review of fact findings, and de novo review of legal conclusions.

2. Applying the standard to Griffin’s application. The Act allows district judges to review the application, any materials submitted, and “relevant records in the possession of the judicial branch.” The district court consulted the application and Minnesota appellate decisions in Griffin’s case and found no reasonable probability that Griffin did not cause the death. The Supreme Court affirms, emphasizing:

  • Record-based causation: Griffin I’s “circumstances proved” narrative supports that Griffin fired the fatal shot intentionally. Griffin’s own prior appellate briefing conceded he fired the shot, arguing only accidental discharge. The record, therefore, powerfully contradicts the Act’s first prong (“did not cause the death”).
  • No new evidence: Griffin supplied no new materials that would undermine prior factual determinations or create a reasonable probability that he was not the shooter.
  • Harmless misstatement below: The district court incorrectly asserted that the jury specifically found Griffin to be the shooter. Because the verdict followed hybrid instructions, it did not specify a theory of liability. The Supreme Court acknowledges this error but finds it immaterial to the result, given that the broader record—especially Griffin I—amply demonstrates causation by Griffin.

3. Issues reserved. The court deliberately declines to define the Act’s “reasonable probability” standard and leaves open whether a hybrid-instruction verdict satisfies the Act’s requirement that the conviction be “under the theory of liability for crimes of another.” Those questions await a case that squarely presents them.

Impact and Forward-Looking Considerations

A. A clear appellate standard—and significant deference. By adopting abuse-of-discretion review for preliminary denials under the Act, the court sets a deferential posture. Applicants will face substantial headwinds on appeal unless they can show the district court misapplied the law or ignored the record. This favors early development of a robust application with concrete evidentiary support.

B. The centrality of the existing judicial record. District courts may, and likely will, lean heavily on prior trial records and appellate decisions when assessing the “reasonable probability” threshold. Where earlier opinions have already found (or accepted concessions) that the applicant was the shooter, applicants must supply compelling new evidence to create a reasonable probability that they did not cause the death.

C. Hybrid-instruction convictions: eligibility remains an open battleground. Many pre-2020 convictions employed hybrid principal/accomplice instructions. Because the Act’s relief is limited to those “convicted … under the theory of liability for crimes of another,” defendants with ambiguous verdicts may contest eligibility. The court’s decision to assume eligibility without deciding signals active litigation terrain ahead.

D. Unresolved meaning of “reasonable probability.” The court flagged but did not define the Act’s standard. Future cases may decide whether it mirrors familiar standards (e.g., Strickland’s probability “sufficient to undermine confidence” in the outcome) or something else. Until clarified, practitioners should treat it as a meaningful—but not insurmountable—burden requiring persuasive, concrete showings.

E. Appellate routing clarified by Griffin IV. Although today’s opinion focuses on the merits, practitioners should note that appeals from preliminary denials in first-degree murder cases lie with the Minnesota Supreme Court via the postconviction appeal pathway in Minn. R. Crim. P. 29.02. For other offenses, jurisdictional routing may differ.

F. Practical guidance for applicants and courts.

  • Applicants: Do not rely on ambiguity from hybrid instructions alone. Assemble affidavits, forensic materials, co-defendant statements, or other evidence that directly supports both prongs: you did not cause the death and you did not intentionally aid another with the intent to cause death. Anticipate and address contrary statements and findings from prior appeals.
  • Prosecutors: Develop the “relevant record” before the court—including prior appellate opinions—to show causation and intent. Highlight prior concessions, trial proof and verdict integrity.
  • District courts: Articulate the connection between the Act’s prongs and the record. While harmless misstatements may not require reversal, clarity about the distinction between jury findings and appellate fact recitals can forestall issues on appeal.

Complex Concepts Simplified

  • Aiding-and-abetting felony murder: Under Minn. Stat. § 609.05, a person is criminally liable for a crime committed by another if they intentionally help or encourage the crime. Felony murder under Minn. Stat. § 609.185(a)(3) imposes liability for a killing committed during certain felonies (like aggravated robbery), even without a separate intent-to-kill element for the felony-murder theory. The 2023 Act narrows accomplice liability by providing relief to some who neither caused the death nor intentionally aided a death.
  • The 2023 Act’s relief: The Act permits eligible persons to seek to vacate certain felony-murder convictions obtained under an aiding-and-abetting theory. For first-degree intentional felony murder, an applicant must show both that they did not cause the death and that they did not intentionally aid another with intent to cause a death. The process starts with a “preliminary application,” which a judge may deny if there’s not a reasonable probability the applicant is entitled to relief.
  • “Reasonable probability” (undefined here): A middle-ground standard requiring more than speculation but less than certainty. The Supreme Court did not define it in this opinion, leaving its precise contours open for future cases.
  • Abuse-of-discretion standard: On appeal, the reviewing court will uphold the district court unless the decision rests on a legal error or is illogical against the record. Factual findings are upheld unless clearly erroneous; legal issues are reviewed anew.
  • Hybrid jury instructions: Instructions allowing conviction as either the principal or an accomplice without requiring the jury to specify which. Minnesota has since moved away from these, but many older cases—including Griffin’s—used them, complicating later eligibility questions under the Act.
  • Knaffla and time bars: Minnesota postconviction law often bars claims that were or could have been raised earlier (Knaffla) and imposes strict deadlines. While the Act creates a distinct remedy, arguments unrelated to the Act’s relief are still subject to familiar procedural restrictions.

Conclusion

State v. Griffin establishes a foundational procedural rule for Minnesota’s new aiding-and-abetting felony-murder relief framework: preliminary denials are reviewed for abuse of discretion. In doing so, the court harmonizes the Act with postconviction practice, authorizes reliance on the existing judicial record at the gatekeeping stage, and underscores that prior factual determinations—especially those affirmed on direct appeal—can be dispositive when an applicant alleges they did not cause a death. The court leaves for another day two pivotal questions: the precise meaning of “reasonable probability” in the Act and whether defendants convicted under hybrid instructions qualify as having been “convicted under the theory of liability for crimes of another.”

As practitioners navigate this reform, Griffin signals that success at the preliminary stage will require focused, persuasive showings grounded in new or overlooked evidence—not mere ambiguity from past hybrid verdicts. At the same time, the opinion’s restraint preserves space for future litigants to shape the contours of eligibility and probability under the Act, ensuring continued development of Minnesota’s evolving felony-murder jurisprudence.