Supreme Court of Minnesota

State of Minnesota v. Melissa Madelyne Zielinski

March 25, 2026

Summary

The court held that a district court may summarily deny a first preliminary application for relief under the Act only on the grounds expressly listed in the Act. It further held that a first-degree felony-murder applicant satisfies the reasonable-probability threshold by alleging facts that could lead a rational person to believe the applicant might prove entitlement to relief by a preponderance of the evidence, and that credibility disputes cannot be resolved before an evidentiary hearing. The court reversed the summary denial and remanded for further proceedings.