Scott County Hudson, C.J. Tyrel Lamar Patterson, Appellant, vs. State of Minnesota, Respondent, A250541

Patterson pleaded guilty in 2017 to first-degree felony murder under an aiding-and-abetting theory for his role in a burglary and robbery that ended in James Herron’s death. 1
The 2023 Act allows certain felony-murder defendants to seek relief if they prove they did not cause the death and did not intentionally aid a killing. 2
Patterson obtained a favorable preliminary determination, then petitioned to vacate his conviction and relied mainly on his plea transcript to show he only intended to aid an aggravated robbery. 3
The State opposed relief with transcripts and findings from co-defendant Derrick Smith’s trial, arguing Patterson helped cause Herron’s death and intended the killing. 4
Without holding an evidentiary hearing, the district court credited the Smith-trial materials, found Patterson caused Herron’s death, and denied the petition. 5
The supreme court reversed, holding the district court abused its discretion by making credibility determinations before an evidentiary hearing. 6

Issue	Plaintiff's Argument	Defendant's Argument	Held
May a district court decide a petition under the Act by making credibility findings without a hearing? 7	Patterson said the court had to limit itself to his case record and could not credit Smith-trial evidence.	The State said the court could rely on Smith-trial materials and deny relief without a hearing.	No; the court abused its discretion by making credibility determinations without an evidentiary hearing. 8

State v. Zielinski, 32 N.W.3d 847 (Minn. 2026) (Act proceedings require a hearing before credibility determinations 9)
Green v. State, 35 N.W.3d 1 (Minn. 2026) (postconviction denials are reviewed for abuse of discretion 10)
State v. Griffin, 24 N.W.3d 247 (Minn. 2025) (same abuse-of-discretion standard applies to preliminary applications under the Act 11)
Rhodes v. State, 875 N.W.2d 779 (Minn. 2016) (defines abuse of discretion 12)
Andersen v. State, 913 N.W.2d 417 (Minn. 2018) (district courts may not make credibility determinations without a hearing 13)
State ex rel. Roy v. Tahash, 152 N.W.2d 301 (Minn. 1967) (evidentiary hearing required when material facts remain disputed 14)