Court of Appeals Digest: Feb. 2, 2026

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Civil Precedential

Domestic Relations

Dissolution; New Trial

In these consolidated appeals, appellant-mother challenged the judgment dissolving the parties’ marriage and the District Court’s orders related to appellant’s motion for amended findings, the award of conduct-based attorney fees, and the source of payment for those fees. Appellant argued that the District Court (1) erred by denying her motion for amended findings as untimely, (2) abused its discretion in awarding conduct-based attorney fees to respondent-father, (3) abused its discretion in determining parenting time, and (4) abused its discretion in allocating the parties’ debts.

The Court of Appeals held that a notice of filing of a “decision or order” under Minn. R. Civ. P. 59.03 need not be of a final, appealable decision to trigger that rule’s timing requirements. The District Court did not err in determining that appellant’s motion for amended findings was untimely and did not otherwise abuse its discretion. Affirmed.

A25-0258, A25-0616 Smith v. Smith (Hennepin County)

Eviction

Expungement

In this appeal from the District Court’s orders granting an eviction expungement under Minn. Stat. § 484.014, subd. 3(a)(5), and vacating a money judgment to “effectuate the expungement,” appellant-landlord argued that the orders should be reversed because the entirety of the mandatory portion of the eviction expungement statute, § 484.014, subd. 3(a), is unconstitutional both on its face and as applied. The Court of Appeals held that Minn. Stat. § 484.014, subd. 3(a)(5), is facially unconstitutional because it violates the separation-of-powers doctrine by mandating that the District Court expunge an eviction case three years after the eviction was ordered without a motion by any party. Reversed.

A25-0951 Weidner Apt. Homes v. B.F. (Hennepin County)

Civil Nonprecedential

Civil Rights

Pleading

Pro se appellant challenged the dismissal, for failure to state a claim upon which relief can be granted, of his claims under 42 U.S.C. § 1983, against respondent-state representative. Appellant alleged that respondent unlawfully deprived appellant of his rights to free speech and to petition by blocking/deleting appellant’s posts on respondent’s Facebook page.  Appellant argued that the District Court (1) erred in granting respondent’s motion to dismiss; (2) abused its discretion in awarding respondent costs and attorney fees; (3) exhibited bias against him; and (4) violated his rights by denying his request for in forma pauperis (IFP) status and the imposition of a cost bond. Noting that appellant failed to identify any relevant statute, ordinance, regulation, custom, or usage vesting authority in respondent to speak on the state’s behalf, the Court of Appeals found no error in the dismissal of appellant’s action. Affirmed.

A25-0329 Zinda v. Heintzeman (Crow Wing County)

Education

Student Discipline

In this appeal following a university disciplinary process for use of ChatGPT during an exam, relator, a Ph.D. student, argued that the university failed to follow its internal procedures, violated his substantive- and procedural-due-process rights, and made findings that were not supported by substantial evidence. The Court of Appeals concluded that the university’s findings were supported by substantial evidence, that the university followed its internal procedures and did not violate relator’s due-process rights. Affirmed.

A25-0342 Univ. of Minn. v. Yang (Univ. of Minn.)

Trusts

Trust Interpretation

In this trust dispute, appellant argued the District Court erred by: (1) interpreting an irrevocable trust agreement as distributing trust property to the trust beneficiaries as tenants-in-common and (2) granting summary judgment in favor of respondents without addressing the validity of an alleged option to purchase trust property. The Court of Appeals concluded that the phrase “in equal shares” was unambiguous when read in the appropriate context of distributing the trust’s remaining real property. Affirmed.

A25-1127 In re Trust of Ronning (Becker County)

Civil Order Opinions

Municipalities

Review

In this certiorari appeal, relators argued that respondent city erred by (1) denying their administrative appeal application seeking review of the city’s permitting decisions that approved in-ground solar facility installations by their neighbor, and (2) granting the subject permits. Respondents countered that, among other things, the court lacked subject-matter jurisdiction over this appeal because relators have an alternative avenue of judicial review in the District Court under Minn. Stat. § 462.361, subd. 1. The Court of Appeals agreed and determined it lacked certiorari jurisdiction over this appeal. Appeal dismissed.

A25-0542 Dunn v. City of Vadnais Heights (City of Vadnais Heights)

Firearms

Rights Restoration

Appellant challenged the District Court’s order denying his petition for reconsideration of respondent sheriff’s denial of his permit application to purchase a firearm. Noting that appellant was contesting the validity of his guilty plea, and that he therefore was required to file for postconviction relief in the criminal proceeding, the Court of Appeals found no error. Affirmed.

A25-0721 In re Restoration of Rights of Tamm (Todd County)

Criminal Precedential

Controlled Substance Crimes

Tribal Enforcement

Defendant challenged the denial of his motion to dismiss a charge of cannabis possession in the first degree, arguing that the statute criminalizing his possession of cannabis flower was civil/regulatory in nature under Public Law 280 and was therefore not enforceable against defendant as an enrolled member of the White Earth Band of Ojibwe. Defendant also argued that cannabis possession was a sovereign right reserved in the 1855 Treaty between the Ojibwe and the United States, which additionally bars his prosecution.

The Court of Appeals held that, because the state has adopted legislation decriminalizing the possession of cannabis flower by adults below certain quantities statewide and has authorized Tribal compacts for the regulation of cannabis by Minnesota’s Tribal governments, Minn. Stat. § 152.0263, subd. 1(1), is a civil/regulatory statute, which the state lacks jurisdiction to enforce against an enrolled member of the White Earth Band of Ojibwe for the possession of cannabis flower occurring within the territorial boundaries of the White Earth Reservation. Affirmed.

A25-0527 State v. Thompson (Mahnomen County)

Criminal Nonprecedential

Assault

Correctional Facilities

In this direct appeal from the judgment of conviction for fourth-degree assault of a correctional employee, defendant argued that the evidence was insufficient to prove that the Isanti County jail is a correctional facility and that the correctional employee was performing a duty imposed by law, policy, or rule. Noting that the jury saw the jail’s interior on the video evidence, and defendant admitted on the body-worn camera recording that he was currently “living” in the jail, the Court of Appeals concluded that the evidence was sufficient to prove that the jail was a “correctional facility” as that term was defined. Affirmed.

A25-0545 State v. Fuhol (Isanti County)

Controlled Substance Crimes

Sufficiency of the Evidence

In this direct appeal, defendant challenged her conviction for felony fifth-degree controlled-substance crime. Defendant argued that the state’s evidence was insufficient to prove beyond a reasonable doubt that she (1) knowingly possessed a controlled substance, and (2) possessed 0.25 grams or more of a controlled substance, the amount required to support a felony-level conviction. The Court of Appeals concluded that the evidence was sufficient to show defendant possessed the controlled substance, which was found connected by a magnet to the exterior of the rear driver-side door of the car she was driving, slightly behind and below the driver’s window. Affirmed.

A24-2024 State v. Boyum (Sherburne County)

DWI

Felonies

In 2023, petitioner pleaded guilty to and was convicted of one charge of second-degree driving while impaired (DWI) and two charges of first-degree DWI in three different cases. At his plea hearing, petitioner admitted that his driver’s license had been revoked or canceled on three prior occasions. In 2024, petitioner petitioned for postconviction relief. He argued that his two first-degree DWI convictions had been erroneously enhanced to felonies based on the prior revocations and cancellation of his driver’s license. He also argued that the statute requiring the imposition of a five-year term of conditional release was unconstitutional. The postconviction court denied petitioner’s petition. The Court of Appeals concluded that petitioner’s DWI convictions were properly enhanced and that his constitutional challenge to the conditional-release statute was without merit. Affirmed.

A25-0694 Vogel v. State (Beltrami County)

Evidence

Lay Opinion

A jury found defendant guilty of mistreatment of an animal based on evidence that he injured a dog. Defendant argued that the District Court erred by admitting the deputies’ testimony that the dog appeared to have been hit or struck. Noting that the deputies’ testimony was rationally based on their perceptions, the Court of Appeals concluded that the District Court did not err by allowing sheriff’s deputies to testify that, based on their observations of the dog, it appeared that the dog had been hit or struck. Affirmed.

A25-0212 State v. Remer (Wright County)

Evidence
Lay Opinion

In connection to a shootout at a club, the state charged defendant with first-degree riot, second-degree murder as part of a drive-by shooting, and ineligible possession of a firearm. At trial, the District Court permitted two police sergeants to identify defendant in and then narrate surveillance footage of the event. The jury found defendant guilty of all three counts. Defendant then petitioned for postconviction relief, arguing that he received ineffective assistance of counsel because his attorney misinterpreted a piece of the state’s ballistic evidence. The postconviction court denied his claim, as it was not persuaded that defendant’s counsel misunderstood the evidence. Defendant appealed, arguing that the District Court erred in admitting the sergeants’ identifications because they constituted improper opinions of guilt and were unhelpful to the jury, and that the postconviction court abused its discretion by denying defendant relief. The Court of Appeals concluded that the District Court did not abuse its discretion in permitting the sergeants to identify defendant in and narrate the surveillance footage because this testimony constituted factual lay opinions that were helpful to the jury. Furthermore, the postconviction court’s finding that defendant’s attorney understood the difference between a 9-millimeter and a .38-caliber-class bullet at trial was supported by the record and defendant was not prejudiced by his attorney’s alleged shortcomings. Affirmed.

A23-0946 State v. Solomon (Hennepin County)

Evidence

Relevance

In this direct appeal from a judgment of conviction for unlawful possession of a firearm and fifth-degree controlled-substance possession, defendant argued that the District Court abused its discretion by permitting testimony about drug sales and gang activity. Defendant additionally contended that he received ineffective assistance of counsel because his trial counsel implicitly conceded his guilt during closing argument without defendant’s acquiescence. Noting that defendant’s presence in proximity to drug sales advanced the likelihood that he unlawfully possessed drugs, and that the testimony gave context for defendant’s decision to flee after being approached by law enforcement, the Court of Appeals concluded that the evidence was relevant and not unfairly prejudicial. Furthermore, defendant’s trial counsel did not concede guilt. Affirmed.

A25-0192 State v. Williams (Hennepin County)

Fleeing an Officer

Sufficiency of the Evidence

In this direct appeal from a final judgment of conviction for fleeing a police officer in a motor vehicle, defendant argued: (1) that the arresting officer, who was the state’s sole witness at trial, made only a fleeting and limited observation of the driver, which was uncorroborated and insufficient to prove beyond a reasonable doubt that defendant was the person operating the vehicle; and (2) that the District Court plainly and prejudicially erred by admitting unobjected-to testimony and allowing argument about defendant’s booking photos, which defendant claimed was unnoticed, unproven, and unfairly prejudicial Spreigl evidence. The Court of Appeals concluded that the direct evidence of the officer’s observation of defendant was sufficient to establish defendant’s guilt by showing that she was the person operating the vehicle. And the District Court did not plainly err by admitting testimony and allowing argument about defendant’s booking photos. Affirmed.

A25-0176 State v. Vredenburg (Olmsted County)

Hearsay

Residual Exception

Defendant appealed from the judgment of conviction for second-degree criminal sexual conduct. He argued that (1) the District Court erred by admitting hearsay statements by the complainant under the residual exception to the hearsay rule and under Minn. Stat. § 595.02, subd. 3, and (2) the prosecutor committed misconduct by eliciting vouching testimony from two expert witnesses as to whether the complainant had been sexually abused. The Court of Appeals concluded that the 5-year-old victim’s statements to her mother and to her therapist were properly admitted under the residual exception to the hearsay rule. Furthermore, any vouching testimony was either not error or was harmless. Affirmed.

A25-0344 State v. Ramirez (Lyon County)

Illegal Firearm Possession

Constitutionality

In this appeal from the District Court’s order denying postconviction relief from his conviction for felony threats of violence, pro se petitioner argued that the District Court erred by declining to address the constitutionality of Minnesota’s firearm-prohibition laws because his requested relief amounted to an advisory opinion. Noting that petitioner did not allege that he inherited, was gifted, or purchased an antique firearm, the Court of Appeals concluded that petitioner did not have standing because he has not shown any actual, injury-in-fact stemming from the statute prohibiting certain persons from possessing firearms. Affirmed.

A25-0896 LaFrance v. State (Polk County)

Juveniles

Continuances

Appellant was adjudicated delinquent after he pleaded guilty to spray-painting and vandalizing several public and private spaces in Rochester. The District Court denied his motion to continue adjudication and appellant appealed, advancing two arguments. Appellant argued first that the District Court exceeded its authority by considering factors beyond the plain language of the continuance statute. Second, appellant contended that the court failed to meaningfully consider evidence of public safety and his best interests. The Court of Appeals concluded that the District Court did not exceed its statutory authority by considering factors other than public safety and appellant’s best interests and did not abuse its discretion by failing to continue the case without adjudication. Affirmed.

A25-0771 In re Welfare of E.W.H. (Olmsted County)

Murder

Jury Instructions

Defendant challenged his convictions for felony murder, first-degree assault, and ineligible person in possession of a firearm or ammunition, asserting, inter alia, that the District Court abused its discretion when it denied his request to include heat-of-passion manslaughter as a lesser-included offense in the jury instructions. Noting that there was no speculation as to whether the victim injured defendant, the Court of Appeals agreed with the District Court that defendant could not satisfy the provocation prong and concluded that the District Court did not abuse its discretion by denying defendant’s request for a heat-of-passion jury instruction. Affirmed.

A23-1389 State v. Craig (Hennepin County)

Plea Withdrawal

Accuracy

In this appeal from an order denying postconviction relief, petitioner argued that the District Court abused its discretion by denying his request to withdraw his guilty plea to second-degree assault—fear (dangerous weapon) because the plea was inaccurate. Noting that petitioner admitted to threatening to stab the victim while holding a knife, the Court of Appeals concluded that petitioner’s intent to cause fear in another of immediate bodily harm or death was a reasonable inference. Affirmed.

A25-0962 Agar v. State (Otter Tail County)

Plea Withdrawal

Adequate Factual Basis

In this direct appeal from a judgment of conviction for threats of violence, defendant argued that (1) his guilty plea was not accurate because the factual basis did not establish two elements of the offense, (2) the District Court abused its discretion in denying his presentencing motion to withdraw his guilty plea as involuntary, and (3) the District Court erred by assigning three criminal-history-score points for offenses committed as part of a single course of conduct involving multiple victims. The Court of Appeals concluded that, because the facts admitted by defendant during his plea colloquy supported reasonable inferences sufficient to prove reasonable apprehension and conscious disregard, his plea had an adequate factual basis and withdrawal was not warranted on the ground of inaccuracy. However, his sentence must be reversed and remanded for fact-finding on his criminal-history score. Affirmed in part, reversed in part, and remanded.

A25-0521 State v. Lenear (Wright County)

Plea Withdrawal

Intelligent

This appeal arose from defendant’s conviction for fourth-degree criminal damage to property. Defendant challenged the constitutional validity of her guilty plea, arguing that the District Court failed to advise her of the constitutional rights she would be waiving by pleading guilty before accepting her plea. Noting that the District Court advised defendant of only one of the constitutional rights she would waive by entering a guilty plea, and the record did not otherwise establish that her plea was valid, the Court of Appeals concluded that the record failed to show that defendant entered her guilty plea intelligently. Reversed and remanded.

A25-0155 State v. Vredenburg (Dodge County)

Plea Withdrawal

Voluntariness

Following a conviction of second-degree criminal sexual conduct and third-degree sale of a controlled substance, petitioner argued that the postconviction court abused its discretion by denying his postconviction petition to withdraw his guilty pleas. Petitioner argued that his pleas were involuntary because defense counsel advised him that, due to his race, he would be convicted at trial and that a conviction at trial would lead to a life sentence for any future federal convictions. Noting that petitioner relied only on his own testimony for support and that the postconviction court found this testimony not credible, the Court of Appeals concluded that petitioner failed to establish that he was entitled to plea withdrawal. Affirmed.

A25-0810 Tooles v. State (St. Louis County)

Plea Withdrawal

Voluntariness

The state charged defendant with two counts of third-degree criminal sexual conduct based on his alleged sexual penetration of a minor, and he pleaded guilty to one count in a negotiated plea deal with the state. Defendant unsuccessfully moved for a rule 20 competency examination and later presented a sentencing memorandum that did not renew his request for a competency examination but argued for a downward dispositional sentencing departure based on his alleged untreated mental-health issues. The District Court denied the departure motion and sentenced defendant to serve 41 months in prison. Defendant argued on appeal that his conviction should be reversed because he entered his guilty plea involuntarily and unintelligently. Noting that the record demonstrated that defendant was neither improperly pressured nor induced into entering his guilty plea and that he understood its consequences, the Court of Appeals concluded that his argument failed. Affirmed.

A25-0402 State v. Ouellette (Stearns County)

Postconviction Relief

Knaffla Bar

This is the third appeal arising from petitioner’s conviction of two counts of felony second-degree murder in connection with the death of a nine-month-old child. This appeal concerned petitioner’s second petition for postconviction relief, which sought to have her conviction vacated based on claims of false testimony. The petition asserted two claims, including that the state’s medical witnesses falsely testified that the child died from abusive head trauma, previously referred to as shaken baby syndrome, and could not have died from natural causes. The postconviction court determined that appellant’s false-medical-evidence claim was procedurally barred under Knaffla and that no exception applied. Noting that petitioner’s false-medical-evidence claim had substantive merit and her failure to raise the claim earlier was not deliberate and inexcusable, the Court of Appeals concluded that the postconviction court abused its discretion by not applying the interests-of-justice exception to the Knaffla procedural bar for this claim. Affirmed in part, reversed in part, and remanded.

A25-0555 Baldwin v. State (Hennepin County)

Probation Revocation

Seriousness of Offense

On appeal from the District Court’s probation-revocation decision, defendant argued that the District Court abused its discretion because its decision lacked supporting evidence, improperly credited the testimony of the state’s witness, and applied an incorrect legal standard. Noting the finding that defendant engaged in a high-speed chase with police resulting in felony fleeting charges, the Court of Appeals discerned no abuse of discretion in the District Court’s determination as to the seriousness of the offense. Affirmed.

A25-0992 State v. Flowers (Crow Wing County)

Prosecutorial Misconduct

Cross-Examination

In this appeal from a final judgment of conviction and sentence for threats of violence, defendant argued that (1) the prosecutor committed reversible misconduct by confronting her with inadmissible evidence during cross-examination and relying on that evidence during closing arguments, (2) the District Court committed reversible error by admitting inadmissible lay-opinion testimony into evidence, and (3) the cumulative effect of these trial errors deprived defendant of a fair trial. Noting that the prosecutor’s question on cross-examination of defendant if she was told to leave the bar was not offered for the truth of the matter asserted but to highlight the discrepancy between defendant’s and the victim’s testimonies and that it was relevant to defendant’s state of mind, the Court of Appeals concluded that the prosecutor did not commit misconduct when he asked defendant about being kicked out of the bar and the no-contact order. Affirmed.

A25-0189 State v. King (Wilkin County)

Prosecutorial Misconduct

Plain Error

This was an appeal from a final judgment of conviction for fifth-degree criminal sexual conduct. Defendant sought reversal and remand for a new trial, claiming that the state committed plain-error prosecutorial misconduct by (1) arguing to the jury that his conduct caused “spiritual” and “soul harm,” (2) misusing Spreigl evidence, (3) asking the jury to protect society, and (4) contending that, if the jury believed the victim, he was guilty. Noting that the references to “spiritual” and “soul harm” were incidental to the summation’s main thrust—that the victim’s account was credible, the Court of Appeals concluded that the state did not commit plain-error prosecutorial misconduct. Affirmed.

A25-0087 State v. Okero (Goodhue County)

Search Warrants

Probable Cause

Defendant challenged his conviction for unlawful possession of a firearm, arguing that the District Court erred by declining to suppress the firearm because the search warrant was not supported by probable cause. Defendant also challenged the District Court’s warrant of commitment requiring him to register as a predatory offender. At the time the District Court issued the warrant, law enforcement was investigating three separate incidents, including: (1) defendant’s child’s overdose death in his home, (2) an incident related to the distribution of drugs, and (3) an incident related to defendant pointing a gun at a female domestic-abuse victim. The Court of Appeals concluded that that the issuing judge had a substantial basis to believe that probable cause existed. However, the District Court erred by requiring defendant to register as a predatory offender. Affirmed in part, reversed in part, and remanded.

A25-0562 State v. Randolph (Hennepin County)

Sentencing

Downward Departures

Defendant appealed from the judgment of conviction for attempted first-degree drug sale, arguing that the District Court abused its discretion in denying her motion for a downward dispositional sentencing departure. Noting that the record made clear that the District Court carefully evaluated the testimony and information before making its determination, the Court of Appeals discerned no abuse of discretion. Affirmed.

A25-0607 State v. Osborne (Cass County)

Traffic Stops

Reasonable, Articulable Suspicion

This was an appeal from the final judgment of conviction for speeding and driving while impaired (DWI). Defendant challenged the District Court’s pretrial order denying his motion to suppress evidence and to dismiss the charges, arguing that the traffic stop was unsupported by reasonable, articulable suspicion. Noting that the deputy testified that he activated his radar unit and determined defendant was driving 12 miles over the speed limit, the Court of Appeals concluded that the deputy provided specific and articulable facts that supported his reasonable suspicion of a traffic violation. Affirmed.

A25-0971 State v. Contreras Hernandez (Sherburne County)

Warrantless Searches

Cell Site Location Information

Defendant was convicted of first-degree driving while impaired (DWI). On appeal, he argued that the District Court erred in denying his motion to suppress evidence because law enforcement violated Minn. Stat. § 626A.42, by obtaining his cell site location information (CSLI) without a search warrant. Noting that defendant’s close friend had contacted 911 expressing concern that defendant was highly intoxicated and driving, the Court of Appeals concluded that CSLI may be obtained without a warrant under Minn. Stat.t § 626A.42, subd. 2(a), if there is an emergency situation involving the risk of death or serious physical harm to the person possessing the cellular phone, and law enforcement in this case had such an objectively reasonable belief. Affirmed.

A25-0184 State v. Johnson (Todd County)

Warrantless Searches

Expectation of Privacy

On appeal from the judgment of conviction for violating a harassment restraining order (HRO), defendant challenged the District Court’s denial of his motion to dismiss the complaint. Defendant argued the District Court erred in denying the motion because his constitutional rights were violated by the warrantless search of the protected party’s home that led to his arrest for violating the HRO. The Court of Appeals held that valid, active court order barring a defendant from a residence eliminates any reasonable expectation of privacy at that residence, and thus, defendant did not have a reasonable expectation of privacy in the home at the time law enforcement conducted the search. Affirmed.

A25-0303 State v. Ozornia (Kandiyohi County)

Warrantless Searches

Inventory

Police officers stopped a car speeding recklessly through a residential neighborhood and arrested the driver, defendant, on an outstanding arrest warrant. The officers then searched defendant’s car and found evidence of marijuana, which the officers in turn cited in part as support for a search warrant to obtain a sample of defendant’s blood or urine for chemicals. Defendant refused to be tested, the state charged him with test refusal, and defendant unsuccessfully moved the District Court to suppress all the evidence obtained from the encounter. The Court of Appeals concluded that the state failed to offer any evidence establishing that the officers conducted the search according to a police-department inventory-search policy. Reversed and remanded.

A25-0166 State v. Ware (Hennepin County)