Opinions
OPINIONS OF THE SUPREME COURT
RELEASED OCTOBER 21, 2026
NOTICE - MEDIA RELEASE TIME IS 10:00 A.M.
A24-0902 Keith Hapana Crow, Appellant, vs. State of Minnesota, Respondent.
Redwood County.
1. The district court abused its discretion when it summarily denied appellant’s preliminary application for relief from a first-degree felony murder conviction under the Act of May 19, 2023, ch. 52, art. 4, § 24, 2023 Minn. Laws 810, 864–68 (the Act), on the grounds that the issues raised in appellant’s preliminary application had “previously been decided” by this court because our previous decision did not resolve whether appellant caused, or aided with the intent to cause, the victim’s death.
2. The summary denial of a preliminary application under subdivision 5(e)–(f) of the Act is distinct from a denial for lack of reasonable probability under subdivision 5(h). Because the district court did not conduct a reasonable probability analysis and the parties have not briefed or argued the question of reasonable probability, we remand to the district court for it to conduct a reasonable probability analysis pursuant to our decision in State v. Zielinski, 32 N.W.3d 847 (Minn. 2026).
3. Appellant’s constitutional and other claims raised in his pro se supplemental briefs do not merit relief.
Reversed and remanded. Justice Karl C. Procaccini.
Concurring in part, dissenting in part, Chief Justice Theodora K. Gaïtas, Justice Sarah E. Hennesy.
Took no part, Justice Reynaldo A. Aligada, Jr.