Perspectives: 25 cases from ‘A’ to ‘Z’ top list for past year

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The past year has had its usual share of interesting and important cases decided by the federal and state courts for Minnesota.

Some were high profile and others were overlooked by many.

In keeping with tradition dating back to the end of the last millenium and spanning this one, here’s an eclectic 25 of them from “A” (appeals by the attorney general) to “Z” (zoning).

AG Appeals

Attorney General Keith Ellison had more than his customary high-profile appellate matters, stemming from the very beginning of the year.

In January, his office successfully represented Secretary of State Steve Simon in a lawsuit concerning the impasse in the state House of Representatives when the 67 DFL members refused to participate after an equal number of Republican denied both sides majority status in the 134-member chamber in Simon v. Demuth 16 N.W.3rd 255 (Minn. 2025). The state Supreme Court unanimously held that the “quorum clause” of Article IV, §13 of the state constitution bars the Legislature from proceeding with fewer than 68 of the 134 members present, a victory for the DFL at the time, which ultimately was resolved with a legislative power-sharing compromise as the House remained deadlocked.

But the AG failed in his effort to get the U.S. Supreme Court to overturn a pair of lower court rulings striking down the Minnesota statute barring issuance of gun permits to individuals under 21 years of age, pursuant to Minn. Stat. § 624.114, subd. 2(b) (2).

The initial blow came when U.S. District Court Judge Kathleen Menandez deemed the measure violative of the “right to bear and keep arms” provision of the Second Amendment in Worth v. Harrington, 666 F.Supp. 3d 917 (D. Minn. 2022) using the “historical tradition” analysis of the U.S. Supreme Court in New York State Pistol & Rifle Assn. v. Bruen, 597 U.S. 1 (2022).

After the 8th U.S. Circuit Court of Appeals affirmed in Worth v. Jacobson, 108 F.4th 677 (8th Cir. 2024), the AG sought certiorari by the Supreme Court, but the court declined to review the ruling, No. 24-782 (April 21, 2025), leaving the Minnesota measure dormant, while similar restrictions have been upheld by some courts and rejected by others, leaving a split in the circuits that may invite future Supreme Court review.

But in another U.S. Supreme Court ruling a month later, the justices vacated and remanded an 8th Circuit ruling in 2024 rejecting qualified immunity in a police excessive force lawsuit by a teenager who was partially blinded by a police projectile during the George Floyd protests in Minneapolis in 2020. In Bauer v. Marks, 145 S.Ct. 2733 (2025), the court remanded the case in light of its prior ruling in Barnes v. Felix, 605 U.S. 73 (2025) establishing a “totality of circumstances” standard in this type of case.

A couple of months later, the AG’s office lost another gun case in State v. Vagle, 24 N.W.3d 481 (Minn. 2025), as the state Supreme Court invalidated the Minnesota law barring homemade untraceable “ghost guns,” Minn. Stat. § 6009.667(3) on grounds that the statute defectively referenced a non-existent federal gun serial number requirement. That ruling followed by a few months a contrary conclusion by the U.S. Supreme Court, which upheld a “ghost gun” regulatory ban by the federal government in Bondi v. VanDerstok, 145 S.Ct. 857 (2025).

In another gun case, the interior of a private vehicle constitutes a “public place” if the vehicle is operated on a public record for purposes of a criminal charge for a BB gun lodged under the driver’s seat, according to a ruling of the Minnesota Supreme Court in Slate v. Bee, 17 N.W.3d 150 (Minn. 2025). The Court upheld a gross misdemeanor charge of not having a permit for carrying a firearm “in public” under Minn. Stat. § 624.7181. Affirming an appellate court reversal of a Ramsey County District Court decision, the court reasoned that the “plain language” of the statute warranted its application to a vehicle in a public location.

“There’s no right way to be twenty-five … you will be happy … exactly when you’re supposed to be.”
Thought Catalog “Read This If” (2016)

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“In numerology, 25 is a symbol of harmony and balance, and can encourage the finding of equilibrium in all aspects of life.”
Philosopher Lesley Francis, “An English Rose in Georgia” (1943)

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“Is there anything in the future that can possibly console us for not being always 25 .”
British poet Lord Byron (1788 – 1824)

Education enigmas

While eschewing passing on the age-restriction gun case from Minnesota, the U.S. Supreme Court did address the merits of an educational law case from Minnesota and answered a pair of other educational enigmas as well.

In A.J.T. v. Osseo Area Schools, Ind. Sch. District No. 279, 605 U.S. 335 (2025), the court unanimously ruled in favor of parents of an epileptic middle school student in Osseo, who sought special accommodations by a later school scheduling under the Individuals with Disabilities Education Act (IDEA), 20 U.S.C. § 1400, et. seq. under the Americans with Disabilities Act (ADA), which requires accommodations for disabled students.

In a unanimous decision written by Chief Justice John Roberts, the court overturned an adverse ruling of Judge Michael Davis of the U.S. District Court, as affirmed by the 8th Circuit, which had upheld the school district’s refusal to grant later class hours for the disabled student on grounds that it did not engage in “bad faith” or “gross misjudgment,” a standard that the chief deemed was too high in reversing and vacating the lower court ruling and remanding the case, a major victory for parents of disabled and special needs students and their children.

The demotion of a middle school principal in Marshall in northwest Minnesota for displaying 30 flags, including a pride flag in the school cafeteria using school funds without official authorization and then following up with an email to staff stating the undertaking was part of his “personal/professional goals” was upheld by the 8th Circuit Court of Appeals in Thomas v. Marshall Public Schools, I.S.D. 413, F.4th 413 (8th Cir. 2025).

Affirming a ruling of U.S. District Court Judge Patrick Schlitz, an appellate panel that included Judge James Loken of Minnesota held that those actions and pro-LGBTQ+ activities were not protected under the First Amendment because the teacher was acting as a public employee “rather than expressing an opinion as a private citizen.”

Public schools in Minnesota may be liable for negligent hiring of personnel who commit on-duty torts as a result of the ruling of the state Supreme Court in Minor Doe 601 v. Best Academy, 17 N.W.3d 464 (Minn. 2025). Summary judgment for a charter school in Minneapolis where a teacher and sports instructor sexually assaulted a student was reversed by the court on grounds that the school did not conduct a pre-hiring background check of the teacher’s history, which included several incidents of sexual abuse at other educational facilities. Overturning decisions of the Hennepin County District Court and the Court of Appeals, the justices unanimously held, in an opinion authored by Judge Paul Thissen, that discretionary immunity under Minn. Stat. § 466.03, subd. 6 did not apply because the hiring of the educator was not “a policy decision.”

Fitness & facilities

Fitness facilities prevailed in a pair of cases. In Lund v. Calhoun Orange Inc., 20 N.W.3d 871 (Minn. 2025). The court affirmed a jury verdict for the defense in a case involving the serious injury suffered by Hennepin County District Court Judge Fred Karasov while working out at a Minneapolis health club. The court upheld the facilities’ exculpation claim immunizing it from all acts of active or passive negligence. Because it was “clear and unequivocal” it barred a negligence claim for failure to properly attend to the stricken jurist claim.

A competitive fitness organization also prevailed in Life Time, Inc. v. Zurich American Ins. Co., 25 N.W.3d 901 (Minn. App. 2025) in its claim for business interruption insurance proceeds in excess of $1 million due losses sustained during the COVID lockdown in 2020. The economic losses due to the pandemic closure were covered by the “interruption by communicable disease” clause of its policy.

Information issues

Two Minnesota appellate court decisions concerned access to information on legal matters.

In Alpha News v. City of Detroit Lakes, 20 N.W.3d 627 (Minn. App. 2025), the appellate court reversed and remanded a Becker County District Court denial of a request by an online publication for access to police documentation concerning state Sen. Nicole Mitchell’s burglary case, which ultimately resulted in her conviction and resignation from office. The tribunal remanded to the lower court to apply a balancing feat of confidentiality versus “public benefit” to determine access to “investigative data” under the Minnesota Government Data Practices Act, Minn. Stat. § 13.82, subd. 7.

The mid-trial decision by the Olmstead County District Court in domestic assault criminal proceedings by prohibiting spectators from entering the courtroom after daily trial proceedings began, except during scheduled breaks, constitute a reversible error warranting reversal and remand in State v. Abukar, 16 N.W.3d 356 (Minn. App. 2025). The action constituted an impermissible courtroom closure in violation of the defendant’s Sixth Amendment right to a public trial.

Landlord litigation

A trio of cases involved landlord-tenant issues.

In Hook & Ladder Apartments, L.P. v. Nalewaja, 25 N.W.3d 867 (Minn. 2025), the Supreme Cout departed from a 30-year-old precedent of the Court of Appeals — Westminster Corp. v. Anderson, 536 N.W.2d 340 (Minn. App. 1995) — by holding that a landlord that receives and accepts rent and subsidy from a public housing authority waives the right to evict a tenant for breach of lease.

The state law requiring expungement of tenant eviction records was deemed unconstitutional by the Court of Appeals in Sela Invs. Ltd., L.I.P. v. J.H., 22 N.W.3d 181 (Minn. App. 2025). Reversing the Hennepin County District Court, the appellate tribunal upheld a challenge by a landlord on grounds that the statutory mandate under Minn. Stat. § 484.014, subd. 3(a)(6) is facially unconstitutional because it violates the separation of powers doctrine reserving such determination to the “inherent authority” of the judiciary to decide litigation and “control” its own records.

But the Supreme Court rejected a landlord challenge to a Minneapolis ordinance prohibiting denial of residential rental to public assistance tenants in Fletcher Properties v. City of Minneapolis, 24 N.W.3d 387 (Minn. 2025). The justices reasoned that proscriptions did not violate any constitutional rights of property owners.

Libel lawsuits

A pair of published decisions by the Minnesota Court of Appeals in libel lawsuits were addressed in the applicability of published decisions of the Uniform Public Expression Protection Act, Minn. Stat. § 554.07, et seq. (UPPEA), the successor to the SLAPP Law.

In Cook v. Trimble, 220 N.W.3d 196 (Minn. App. 2025), the Court of Appeals upheld dismissal by the Hennepin County District Court of a defamation claim by former Minnesota Vikings running back Dalvin Cook against two attorneys and their law firm for statements they made to the media and in court proceedings about a post break-up dispute between the ex-Viking and his former romantic partner.

Addressing UPEPA for the first time, it held that the two defamation claims were properly dismissed by the Hennepin County District Court. It reasoned that statements made in a legal memorandum filed in court were protected by the “judicial proceedings” privilege and extra-judicial statements made to the media were not actionable due to lack of proof of “actual malice” under the New York Times standard. But the court allowed a breach of privacy claim to proceed based on the filing of a confidential settlement agreement.

A defamation suit over a patient’s online criticism of a dentist’s work was allowed to proceed in J&D Dental v. Hou, 26 N.W3d 491 (Minn. App. 2025). The court held that the UPPEA Act did not warrant dismissal of the case, finding that her speech was not on a matter of “public concern.”

Pipeline protesters

A trio of federal and state civil and criminal cases involving pipeline protests yielded victories for the petitioners.

The media “shield law” applicable to confidential news gathering materials was addressed by the Supreme Court in Energy Transfer L.P. v. Greenpeace, Int’l., 23 N.W.3d 554 (Minn. App. 2025), which involved North Dakota oil pipeline interests seeking data from a news organization and journalists regarding activities of protesters that the media refused to disclose under the Free Flow of Information Act, Minn. Stat. § 595.024 – .025. The pipeline claimants claimed that the “shield” measure did not apply because the data was gathered unlawfully. But the court held that the alleged illegal provision did not create an extra statutory exception to the confidentiality provision of the act, but that the lower court could order disclosure upon reversal on remand in with the other provisions of the statute.

In Locke v. County of Hubbard, 2025 WL 2986056 (Minn. App. Oct. 23, 2025)(nonprecedential), the 8th Circuit revived an excessive force civil lawsuit by a pipeline protester in Hubbard County against law enforcement officials who broke up a rowdy demonstration.

In State v. Moore, 2025 WL 301213 (Minn. App. March 11, 2025)(nonprecedential), the Minnesota Court of Appeals reversed the misdemeanor trespass conviction in Aitkin County of a woman who was praying at the site of a pipeline demonstration.

The appellate court also overturned and remanded a criminal conviction of a “pipeline protester” at the same Aitkin County site due to “pervasive” and “unusually serious” prosecutorial misconduct in State v. Vialard, 2025 WL 2388378 (Minn. App. Aug. 18, 2025)(nonprecedential), which included five instances of “conceded misconduct” during testimony and in closing argument that appealed to the jury’s “potential bias” against the defendant.

Tax tussles

The state Supreme Court rejected a lawsuit by a Minneapolis homeowner and taxpayer in Minneapolis who challenged a racist and ethnic preference provision in the city school district’s contract with the teachers union in Clapp v. Sayles-Adams, 15 N.W.3d 648 (Minn. 2025). The court ruled that the taxpayer lacked standing because the disbursement of public funds in connection with that policy was only incidental “to the disputed issue” and, therefore, did not permit taxpayer standing.

Unlike the Clapp case, a taxpayer suit was successful in a tussle against the state’s largest school district, Anoka-Hennepin, by being allowed to pursue a lawsuit challenging the district’s collective-bargaining provision allowing up to 160 hours of paid leave annually for members of the teachers union to engage in union-related work. In Huizenga v. Ind. Sch. Dist. No. 11, 149 F.4th 990 (8th Cir. 2025). The 8th Circuit overturned a lower court decision by U.S. District Court Judge Jerry Blackwell in Minnesota, who ruled that the claimants lacked standing, The appellate tribunal reasoned that the taxpayers had adequately alleged “direct injury” due to the expenditure of public funds to pay for substitute teachers and remanded the case for a second time after an earlier reversal and remand. 44 F.4th (8th Cir. 2022).

An employee of the Minnesota Department of Human Services (DHS) who objected to the deduction of his union dues from his paycheck lost his appeal of an adverse U.S. District Court ruling in Todd v. AFSCME, 2025 WL 561647 (Minn. App. Feb. 20, 2025)(nonprecedential). The court affirmed a decision of U.S. District Court Judge Susan R. Nelson in Minnesota rejecting a claimed First Amendment violation. Because there was no “state action,” the claim was dismissed, as were others that also were not founded on governmental action.

As the year came to an end, so did the case, as the Supreme Court denied a certiorari petition, No. 24-1305 (Dec. 8, 2025).

Zoning Zeal

A zealous group of neighbors of St. Thomas University in St. Paul lost the second round of their challenge to the prospective determination of the city of St. Paul not to require an environmental impact statement (EIS) for the school’s planned multipurpose sports arena complex. The neighborhood, which prevailed in an earlier challenge of the city’s zoning-related decision not to require an EIS, failed in contesting the city’s declination on remand of an earlier ruling by the Minnesota Court of Appeals. This time, the court upheld the city’s refusal to require an EIS on grounds that it was not “arbitrary or capricious” in In re City of St. Paul’s Decision on EIS for St. Thomas, 2025 WL 2588212 (Minn. App. Sept. 8, 2025)(nonprecedential).

These cases reflect the variety of appellate court rulings on civil and criminal litigation in Minnesota during the past year as the first quarter of the 21st century comes to a close.

RELATED: More Perspectives columns

PERSPECTIVE POINTERS

12 More Top 2025 Cases

U.S. v. Lazarro: 8th Circuit rejects constitutional challenge to federal sex-trafficking conviction.

Medtronic v. CSR: 8th Circuit bars IRS from reallocating royalties from foreign subsidiary.

State v. Bienek: State Supreme Court rules that probable cause not needed to obtain warrant for DWI testing.

State v. Martens: State Supreme Court upholds testimony of therapist, as mandated reporter, of defendant’s reported sexual contact with child after child had reached adulthood.

State v. Manska: Supreme Court allows evidence of police car dash camera footage as defense in DWI case.

State v. Nyonteh: Supreme Court upholds dismissal of sleeping juror in sexual abuse case.

State v. Talave: Supreme Court holds that domestic assault statute extends to parties formerly in a romantic relationship.

Warrior v. Acova: Court of Appeals remands outcome in family pharmaceutical business ownership dispute.

Kiya v. Jackson: Court of Appeals upholds Japanese child support order against former Minnesota Twins pitcher.

Wakasugi v. 3M: Appellate Court reverses and remands dismissal of elimination of women’s job after request for pregnancy leave.

Mountjoy v. Fairview Health Services: Appellate Court allows case to proceed with medical malpractice claim for battery after other claims.

Seven Acquisition, LLC v. Williams: Court of Appeals upholds quasi-judicial immunity for court-appointed receiver during foreclosure.

Marshall H. Tanick is an attorney with the Twin Cities law firm of Meyer, Njus, Tanick, Linder & Robbins, PA.