State of Minnesota v. Scot Perry Christian

Summary

The Minnesota Supreme Court affirmed the denial of Scot Perry Christian’s preliminary application for relief from two first-degree felony murder convictions under a 2023 statutory relief provision. The court held that the trial evidence, together with Christian’s concession on appeal that he told his accomplice to shoot, established that he intentionally aided or advised the killing. Accordingly, the district court did not abuse its discretion in finding no reasonable probability that Christian was entitled to relief.

Holdings

1. An applicant seeking preliminary relief from a first-degree felony-murder conviction must allege facts that would cause a rational person to believe the applicant might prove by a preponderance of the evidence that he neither caused nor intentionally aided, advised, hired, counseled, conspired with, or procured another with the intent to cause a human death. Christian's allegations were insufficient because the trial record and his appellate concession established that he intentionally aided or advised Powers to cause a death.
2. The district court did not abuse its discretion by denying Christian's preliminary application.

Questions Presented

1. Whether the district court abused its discretion by denying Christian's preliminary application for relief under the 2023 Act because there was no reasonable probability that he could prove he neither caused nor intentionally aided, advised, counseled, conspired with, or procured another to cause a human death.

Disposition

affirmed