John Lee Edmondson v. State of Minnesota

Court of Appeals of Minnesota·Decided August 24, 2026·No. a252059·Published

Opinion

STATE OF MINNESOTA

IN COURT OF APPEALS

A25-2059

John Lee Edmondson, petitioner, Appellant,

vs.

State of Minnesota,

Respondent.

Filed August 24, 2026

Reversed and remanded

Larson, Judge

Ramsey County District Court File No. 62-K4-93-003107

Cathryn Middlebrook, Chief Appellate Public Defender, St. Paul, Minnesota (for appellant)

Keith Ellison, Attorney General, St. Paul, Minnesota; and

John J. Choi, Ramsey County Attorney, Michelle A. Monteiro, Assistant County Attorney, St. Paul, Minnesota (for respondent)

Considered and decided by Harris, Presiding Judge; Frisch, Chief Judge; and Larson, Judge.

SYLLABUS

An applicant with a qualifying aiding-and-abetting-felony-murder conviction (qualifying felony-murder conviction) who is in the custody of the commissioner of corrections or under court supervision may submit a preliminary application for relief from that conviction, even if the applicant is not in the custody of the commissioner of

corrections or under court supervision for the qualifying felony-murder conviction from which the applicant seeks relief.

OPINION

LARSON, Judge In 2023, the legislature enacted a process that allows a person with a qualifying felony-murder conviction to petition the district court to vacate that conviction. 2023 Minn. Laws ch. 52, art. 4, § 24, at 864-68, amended by 2024 Minn. Laws ch. 123, art. 4, §§ 19-21, at 2268-71 (the Act). 1 The Act provides that:

Any person convicted of a violation of [Minn. Stat § 609.185(a)(3)], or [Minn. Stat. § 609.19, subd. 2(1)], under the theory of liability for crimes of another and who is in the custody of the commissioner of corrections or under court supervision is entitled to petition to have the person’s conviction vacated pursuant to this section.

2023 Minn. Laws ch. 52, art. 4, § 24, subd. 1, at 864 (emphasis added). To obtain retroactive relief, an eligible person must first file a “preliminary application” in district court. Id., subd. 4, at 865.

Appellant John Lee Edmondson appeals the district court’s decision to summarily deny his preliminary application. Specifically, Edmondson contests the district court’s determination that the phrase “who is in the custody of the commissioner of corrections or under court supervision” requires that the applicant be in custody or under supervision for

1 The Act is not codified in the Minnesota statutes, likely because the application procedure for seeking relief from a qualifying felony-murder conviction is time-limited. See Raisch v. State, 8 N.W.3d 237, 242 n.3 (Minn. App. 2024) (discussing the 2023 session law), rev. denied (Minn. Nov. 19, 2024); see also 2024 Minn. Laws ch. 123, art. 4, § 21(c), at 2271 (extending the deadline for certain persons seeking relief to October 1, 2026).

the conviction from which relief is sought. Because we agree with Edmondson that the Act’s plain language does not provide for such a limitation, we reverse and remand.

FACTS

Following a jury trial in 1994, Edmondson was convicted of aiding and abetting second-degree felony murder under Minn. Stat. § 609.19, subd. 2 (1992), and aggravated robbery under Minn. Stat. § 609.245 (1992). The district court sentenced Edmondson to a 225-month prison term for aiding and abetting second-degree felony murder and to an 87- month prison term for aggravated robbery. Edmondson filed a direct appeal, and we affirmed his convictions and sentences. State v. Edmondson, No. C0-94-1708, 1995 WL 254354, at *1 (Minn. App. May 2, 1995), rev. denied (Minn. June 29, 1995).

On May 20, 2017, Edmondson completed his sentences for the 1994 convictions.

Thereafter, Edmondson was convicted of second-degree intentional murder for an offense that occurred in February 2023. Edmondson was sentenced to a 480-month prison term. 2 He is currently in the custody of the commissioner of corrections serving this sentence.

On September 25, 2026, Edmondson filed a preliminary application under the Act to vacate his 1994 qualifying felony-murder conviction. The district court summarily denied Edmondson’s preliminary application. The district court concluded that Edmondson was not entitled to relief because, at the time he filed his preliminary application, he was not in custody for the 1994 conviction. The district court reasoned that,

2 Edmondson appealed this sentence, and that appeal is currently pending in our court. See State v. Edmonson, No. A25-1681.

despite such limiting language not appearing in the Act, allowing a person in Edmondson’s position to submit a preliminary application would be an absurd result.

Edmondson appeals.

ISSUE

Did the district court abuse its discretion when it summarily denied Edmondson’s preliminary application on the ground that he was not in the custody of the commissioner of corrections for the conviction from which he sought relief?

ANALYSIS

Edmondson challenges the district court’s decision to summarily deny his preliminary application. We review a district court’s decision to summarily deny a preliminary application for an abuse of discretion. State v. Zielinski, 32 N.W.3d 847, 856 (Minn. 2026). An abuse of discretion occurs when a decision “is based on an erroneous view of the law or is against logic and the facts in the record.” State v. Griffin, 24 N.W.3d 247, 255 (Minn. 2025) (quotation omitted). We review findings of fact for clear error and legal conclusions de novo. Id.

As discussed above, the Act allows a person with a qualifying felony-murder conviction to petition the district court to vacate that conviction. 2023 Minn. Laws ch. 52, art. 4, § 24, at 864-68, amended by 2024 Minn. Laws ch. 123, art. 4, §§ 19-21, at 2268-71. The Act sets forth a series of steps that must occur before it can be determined that an applicant is entitled to relief.

“In the first step, the applicant must submit a preliminary application to the district court seeking permission to petition to vacate the felony murder conviction.” Zielinski, 32

N.W.3d at 854. The “preliminary application must contain certain identifying and procedural information . . . and ‘a brief statement . . . explaining why the applicant is entitled to relief under [the Act].’” Id. (citation omitted).

At the outset, the district court may “‘summarily deny’ a preliminary application in certain scenarios.” Id. at 856; see also Griffin, 24 N.W.2d at 251 n.4 (noting a distinction between “summarily” denying a preliminary application and denying a preliminary application). Specifically, summary denial can occur if: (1) “the application does not contain the [required] information”; (2) “the applicant is not in the custody of the commissioner of corrections or under court supervision”; (3) “the applicant was not convicted of a violation of [Minn. Stat. § 609.185(a)(3)] or [Minn. Stat. § 609.19, subd. 2(1)], for crimes committed before August 1, 2023”; (4) “the issues raised in the application are not relevant to the relief available under [the Act] or have previously been decided by the court of appeals or the supreme court in the same case”; or (5) the applicant previously filed a preliminary application for the same conviction. 2023 Minn. Laws ch. 52, art. 4, § 24, subd. 5(e), (f), at 866 (emphasis added). One of these five circumstances must exist for a district court to summarily deny a preliminary application. See Zielinski, 32 N.W.3d at 856-57.

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