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.