Cameron Oneal Clark, petitioner, Appellant,

This opinion is nonprecedential except as provided by
Minn. R. Civ. App. P. 136.01, subd. 1(c).

STATE OF MINNESOTA
IN COURT OF APPEALS
A25-1812

Cameron Oneal Clark, petitioner,
Appellant,

vs.

State of Minnesota,
Respondent.

Filed June 29, 2026
Affirmed
Larson, Judge

Hennepin County District Court
File No. 27-CR-21-8343

Cameron O’Neal Clark, Rush City, Minnesota (self-represented appellant)

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

Mary F. Moriarty, Hennepin County Attorney, Matthew D. Hough, Assistant County
Attorney, Minneapolis, Minnesota (for respondent)

Considered and decided by Larson, Presiding Judge; Wheelock, Judge; and Bond,
Judge.

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NONPRECEDENTIAL OPINION
LARSON, Judge
Self-represented appellant Cameron O’N eal Clark 1 filed a petition for
postconviction relief based on witness recantation. Following an evidentiary hearing, the
district court denied the petition, and Clark appeals. Because we conclude the district court
did not abuse its discretion when it denied Clark’s postconviction petition, we affirm.
FACTS
Following a jury trial in 2021, Clark was convicted of first-degree attempted murder
of an unborn child and first-degree aggravated robbery. A.H. and Clark were in a
relationship, and A.H. was pregnant.2 A.H. visited Clark at an apartment complex when
Clark and another individual attacked her. Clark kicked A.H. all over her body and tased
her on the stomach and back. A.H. identified Clark as one of the assailants and testified
that Clark knew she was pregnant at the time of the attack. Clark filed a direct appeal
challenging his convictions, and we affirmed. State v. Clark, No. A22-0009 (Minn. App.
Dec. 12, 2022), rev. denied (Minn. Mar. 14, 2023).
In July 2024, Clark filed a petition for postconviction relief, arguing he was entitled
to a new trial because A.H. had recanted. A.H. submitted an affidavit in support of Clark’s

1 The district court case caption identifies appellant as “Cameron Oneal Clark.” Appellant
identifies himself as “Cameron O’Neal Clark” in his brief. The caption of this opinion
conforms to the caption used in the district court. See Minn. R. Civ. App. P. 143.01. But
we use appellant’s preferred name in the body of the opinion.
2 It is unclear whether Clark and A.H. were still in a relationship when Clark sought
postconviction relief. A.H. testified at the evidentiary hearing before the district court.
When asked whether she and Clark were “still romantically involved,” A.H. stated that she
“prefer[red] not to answer that question.”
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petition acknowledging that she named Clark “as [her] assailant” but now “wish[ed] to
recant.” In the affidavit, A.H. explained that she was in an emotional state after the attack
due to her pregnancy and separation from Clark, which affected her clarity at the time she
accused Clark. The state opposed Clark’s postconviction petition.
The district court granted Clark’s request for an evidentiary hearing at which Clark
had legal representation. There, A.H. testified that she was “unsure” whether Clark
attacked her. She stated that “in the moment,” she “believed it was him,” but now she
doubted her identification after having “time to think over the situation.” The state
questioned A.H. about an order for protection (OFP) she sought against Clark following
the assault and jail calls made between her and Clark in December 2024. In addition to
A.H.’s testimony, the district court received: police reports; A.H.’s affidavit and petition
for an OFP following the assault; a child-support order involving Clark and A.H.’s shared
child; a transcript of A.H.’s trial testimony; and call logs, recording s, and transcripts of
three jail calls between Clark and A.H. in December 2024.
Following the evidentiary hearing, the district court denied Clark’s postconviction
petition, finding A.H.’s hearing testimony “wholly incredible” and her affidavit recantation
“not genuine.” Thus, based upon the evidence, the district court determined it had “no
reason to believe that A.H.’s trial testimony was false.”
Clark appeals.
DECISION
Clark challenges the district court’s decision to deny his postconviction petition.
We review a district court’s decision to deny a postconviction petition for an abuse of
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discretion. Williams v. State, 5 N.W.3d 399, 405 (Minn. 2024). A district court abuses its
discretion when it has “exercised its discretion in an arbitrary or capricious manner, based
its ruling on an erroneous view of the law, or made clearly erroneous factual findings.”
Pearson v. State, 891 N.W.2d 590, 596 (Minn. 2017) (quotation omitted).
Clark argues the district court abused its discretion when it determined that his
witness-recantation claim did not entitle him to relief. When a petitioner raises a witness -
recantation claim, Minnesota courts apply the three-prong Larrison test.3 See Andersen v.
State, 940 N.W.2d 172, 178 (Minn. 2020). T o satisfy the Larrison test, a petitioner must
establish the following by a preponderance of the evidence: “(1) the court must be
reasonably well-satisfied that the testimony in question was false; (2) without that
testimony the jury might have reached a different conclusion; and (3) the petitioner was
taken by surprise at trial or did not know of the falsity until after trial.” Id. The first two
prongs are mandatory, but the third prong is not required for relief. Kaiser v. State, 4
N.W.3d 95, 103 (Minn. 2024).
Here, the district court determined that Clark did not meet his burden to establish
the first Larrison prong. A petitioner meets their burden on the first Larrison prong when
the district court is “reasonably certain that the recantation is genuine.” State v. Walker ,
358 N.W.2d 660, 661 (Minn. 1984). The district court can consider the circumstances
surrounding a recantation when evaluating the first Larrison prong. See id. Clark argues

3 Although Larrison was overruled, see Larrison v. United States, 24 F.2d 82, 87-88
(7th Cir. 1928), overruled by United States v. Mitrione, 357 F.3d 712, 718 (7th Cir. 2004),
Minnesota courts continue to apply the Larrison test to witness-recantation claims. See
State v. Duol, 25 N.W.3d 135, 139 n.4 (Minn. 2025).
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the district court abused its discretion in its analysis of the first Larrison prong, raising two
arguments.
First, Clark asserts the district court’s decision conflicts with the supreme court’s
decisions in State v. Al-Naseer, 788 N.W.2d 469 (Minn. 2010), and State v. Caldwell,
322 N.W.2d 574 (Minn. 1982). But the supreme court did not evaluate a witness-
recantation claim or apply the Larrison test in Al-Naseer. 788 N.W.2d at 473-81. And
Caldwell is distinguishable because the supreme court applied the Larrison test to evaluate
a false-testimony claim, not a witness-recantation claim. 322 N.W.2d at 587. Because
neither case applies the Larrison test in the witness-recantation context, we are not
persuaded that either case supports Clark’s claim that the district court abused its
discretion.
Second, Clark contends the district court abused its discretion because its decision
was contrary to the evidence presented at the evidentiary hearing. Specifically, Clark
argues the record “presents nothing to infer [ A.H.] was induced by [Clark] to recant her
trial testimony.” We disagree. The state admitted three jail calls wherein Clark discussed
recanted testimony and the postconviction process with A.H. Then, at the evidentiary
hearing, A.H. claimed that she could not recall whether these conversations occurred. See
State v. Hill, 253 N.W.2d 378, 384 (Minn. 1977) (“Courts have traditionally looked with
disfavor on motions for a new trial founded on alleged recantations . . . .”).
Moreover, the district court’s explanation for why it was not “reasonably certain
that the recantation [was] genuine” is well supported by the record. See Walker, 358
N.W.2d at 661. As the district court observed, A.H.’s recantation was a noticeable
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departure from her trial testimony. And the state presented corroborating evidence at trial
to support A.H.’s trial testimony.
For these reasons, we conclude the district court did not abuse its discretion when it
denied Clark’s postconviction petition.
Affirmed.