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Court of Appeals Digest: Feb. 17, 2026

Minnesota Lawyer//February 19, 2026//

The Minnesota Judicial Center

The Minnesota Judicial Center stands in the Capitol complex in St. Paul. (File photo: Bill Klotz)

Court of Appeals Digest: Feb. 17, 2026

Minnesota Lawyer//February 19, 2026//

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Civil Nonprecedential

 

Civil Commitment

Mental Illness; Sufficiency of the Evidence

On appeal from an order for civil commitment, appellant argued that (1) there was insufficient evidence to support a finding that she posed a significant risk of harm to herself or others, (2) the order conflicted with a prior order denying a judicial hold based on a lower evidentiary standard, and (3) the District Court erred by concluding that there were no suitable less-restrictive alternatives to commitment. Noting that there was sufficient support in the record to justify the District Court’s finding that appellant ingested Propranolol with intent to engage in self-harm, the Court of Appeals concluded that clear and convincing evidence supports the District Court’s determination that appellant posed a substantial likelihood of physical harm. Furthermore, the commitment order was not inconsistent with a previous order and the District Court did not improperly determine that there were no less-restrictive alternatives to commitment. Affirmed.

A25-1637 In re Civ. Commitment of Atterberry (Hennepin County)

 

Common Interest Communities

Interpretation

 

Appellants, owners of an undeveloped lot, challenged the District Court’s grant of summary judgment in favor of respondent homeowners’ association, arguing that the District Court erred when it determined that respondent’s denial of appellants’ home-design application was consistent with the association’s governing documents. The Court of Appeals discerned no error in the District Court’s interpretation of the applicable provisions of the HOA documents. Affirmed.

A25-1129 Warner v. Pines of N. Oaks Home Owners’ Assoc., Inc. (Ramsey County)

 

 

Conservatorship

Accounting

Pro se appellant was the spouse of a protected person and sought review of the District Court’s denial of her motion to reconsider a final accounting by respondent, the protected person’s conservator. The Court of Appeals concluded that appellant forfeited her challenges to the final accounting and that the District Court did not abuse its discretion by denying her motion to reconsider. Affirmed.

A25-0807 In re Guardianship & Conservatorship of Rietveld (Itasca County)

 

 

Domestic Relations

Child Custody; Sole Custody

In this parenting dispute, appellant-father argued that the District Court abused its discretion in awarding respondent-mother sole custody, failed to give adequate weight to appellant’s evidence of parental alienation, put excessive weight on speculative testimony, abused its discretion in restricting appellant’s parenting time, and failed to make adequate best-interest findings. Noting the District Court’s findings of a significant history of conflict and communication struggles, the Court of Appeals concluded that the District Court’s findings supported its conclusion that joint legal custody would not be in the children’s best interests. Affirmed.

A25-0413 Menday v. Silvano (Polk County)

 

 

Domestic Relations

Child Protection; Termination of Parental Rights

Appellant-father challenged the termination of his parental rights. The Court of Appeals concluded that the evidence supported the finding that the child suffered egregious bodily harm while in appellant’s care and that termination of appellant’s parental rights was in the child’s best interests. Affirmed.

A25-1222 In re Welfare of Child(ren) of A.F.C. (Dakota County)

 

 

Domestic Relations

Paternity; Genetic Testing

Appellant putative father argued that the District Court erred by (1) misapplying res judicata and collateral estoppel to dismiss his parentage proceeding; (2) denying his motion for genetic testing; (3) misapplying the Safe-Place-For-Newborns statutes; (4) violating his procedural and substantive due-process rights; and (5) violating his equal-protection rights. The Court of Appeals concluded that the fact that appellant did not plead that child had no presumptive father did not deprive appellant of standing and that appellant’s affidavit filed with the District Court alleging, among other things, sexual contact between him and the child’s mother resulting in child’s birth, required the District Court to compel genetic testing to determine paternity. Reversed and remanded.

A25-0751 In re Paternity of Female Child (Crow Wing County)

 

 

Health Care

Access to Pharmaceuticals

Appellant, a trade association representing pharmaceutical manufacturers, appealed the District Court’s grant of the state respondents’ motion to dismiss its complaint challenging Minn. Stat. § 62J.96 as unconstitutional. The statute prohibits manufacturers from preventing delivery of a covered entity’s covered outpatient drugs to contract pharmacies for dispensing to the covered entity’s patients. The Court of Appeals concluded that appellant did not plead a viable claim that § 62J.96 violated the Single Subject and Title Clause requirements of the Minnesota Constitution. Furthermore, § 62J.96 was not field preempted by federal law. And, because § 62J.96 does not control the price of manufacturer-to-distributor sales occurring outside of Minnesota, the District Court did not err in dismissing appellant’s dormant Commerce Clause claim. Affirmed.

A25-0805 Pharm. Rsch. & Mfrs. of Am. v. Ellison (Ramsey County)

 

 

Health Care

Public Care Assistance

In this certiorari appeal, relator challenged an order of respondent Department of Human Services (DHS) suspending relator from participating in the Minnesota Health Care Programs relating to fraudulent claims for reimbursement. The Court of Appeals concluded that DHS does not need to conduct the statutory analysis to enforce a prior sanction, and the commissioner did not violate relator’s procedural due-process rights. Affirmed.

A25-0696 In re SIRS Appeal by Midwest Quality Home Care, Inc. (Minn. Dep’t of Hum. Servs.)

 

 

Human Services Licensure

Adult Day Care Services

In this certiorari appeal, relator challenged an order by respondent Commissioner of Human Services revoking relator’s license to provide adult day care services. Relator argued that (1) the commissioner’s determination that relator violated a conditional-license term was arbitrary and capricious and unsupported by substantial evidence, (2) the commissioner’s determination that relator violated ten licensing requirements was based on error of law and unsupported by substantial evidence, and (3) the commissioner’s application of Minn. Stat. § 245A.07, subd. 1(a), was affected by an error of law. Noting the findings that relator violated the participant term of the conditional license, and that these findings were supported by the record, the Court of Appeals concluded that the commissioner’s decision to revoke relator’s license was not arbitrary and capricious, was supported by substantial evidence, and was not affected by an error of law. Affirmed.

A25-0689 In re Appeal of Souriyathay Adult Daycare (Minn. Dep’t of Hum. Servs.)

 

 

Motion Practice

Failure to Comply

This appeal arose from a District Court order granting summary judgment in favor of the moving party pursuant to Minn. Gen. R. Prac. 115.06 based on the nonmoving party’s general failure to participate in litigation. The nonmoving party appealed, arguing that the District Court erred by failing to state its reasons for granting summary judgment as required under Minn. R. Civ. P. 56 and failing to address whether any genuine issues of material fact existed. The Court of Appeals concluded that Rule 115.06 does not permit a District Court to grant summary judgment solely based on the non-moving party’s failure to respond. Reversed and remanded.

A25-1238 MJ Prop. Holdings, LLC v. Solv-All All. Group, LLC (Hennepin County)

 

 

Real Property

Mobile-Home Communities

Pro se appellant, a resident of a mobile-home community operated by respondent, challenged the District Court’s summary-judgment dismissal of his claims, On appeal, appellant argued the District Court: (1) erred when it granted summary judgment in favor of respondents; (2) violated his procedural due-process rights; and (3) abused its discretion when it denied his motion to compel. The Court of Appeals concluded that Minn. Stat. § 504B.441 did not create a right of recovery for appellant based on the fact that the home was listed for sale. Affirmed.

A25-0732 Carmack v. Valley Green Park (Scott County)

 

 

Real Property

Settlements

Pro se appellant mortgagor sought review of the District Court’s order enforcing a settlement agreement with respondent mortgagee along with review of the District Court’s denial of appellant’s motion to vacate the judgment. Appellant argued that this court should reverse the District Court’s order for many reasons, including the following: respondent committed fraud in amending the settlement agreement, resulting in a violation of appellant’s due-process rights; the settlement agreement was procured by economic duress; respondent hindered appellant’s performance; respondent violated notice and inquiry-response requirements under the Real Estate Settlement Procedures Act (RESPA); and appellant did not receive reasonable accommodations under title II of the Americans with Disabilities Act (ADA) during settlement negotiations. The Court of Appeals found no error in enforcing the settlement agreement, noting that appellant offered no evidence of unlawful coercion, and that appellant failed to establish that respondent hindered her performance under the agreement. Affirmed.

A25-1205 Magnifi Fin. Credit Union v. Lewis (Hennepin County)

 

 

Real Property

Third-Party Beneficiaries

This appeal arose from a lawsuit by respondent against appellant and defendants sisters. The lawsuit concerns a right of first refusal (ROFR) that respondent entered into with the sisters’ mother—who has since passed away—concerning real property that mother owned. After their mother’s death and notwithstanding the ROFR, the sisters entered into a purchase agreement to sell the property to appellant. As relevant here, respondent sued the sisters for breach of contract, among other claims. Appellant filed several counterclaims against respondent, including a request for declaratory judgment that the ROFR did not bind the sisters. Respondent moved for summary judgment in its favor, including on its breach-of-contract claim against defendants. Appellant moved for summary judgment in her favor, including on her declaratory-judgment claim against respondent. The District Court granted summary judgment for respondent on its breach-of-contract claim against the sisters and denied appellant’s motion for summary judgment. In this appeal from the resulting final judgment, appellant challenged the District Court’s decision, asserting that the District Court erred in determining that Minn. Stat. § 500.20, subd. 2a, did not invalidate the ROFR 30 years after its creation and that the ROFR bound the sisters. The sisters did not appeal. The Court of Appeals concluded that appellant was not a third-party beneficiary of the ROFR and therefore had no legal basis to challenge the enforceability of the ROFR against the sisters. Affirmed.

A25-0583 DAMHOF Dairy v. Stahnke (Kandiyohi County)

 

 

Unemployment Benefits

Employment Misconduct

Relator challenged a determination by an unemployment-law judge (ULJ) that she was ineligible for unemployment benefits because she was discharged for employment misconduct. Relator argued that (1) the ULJ’s finding of employment misconduct was unsupported by substantial evidence and based on legal error and (2) the ULJ erred in failing to call a witness during the hearing and in denying relator’s request for reconsideration. Noting the finding that relator gave no credible explanation for why she could not use Outlook calendar and other tools, such as reminders on her phone, to help herself keep track of when she had work appointments, the Court of Appeals concluded that that the ULJ’s findings were supported by substantial evidence. Affirmed.

A25-0816 McDuffie v. Assoc. of Minn. Pub. Educ. Radio Stations, Inc. (Dep’t of Emp’t & Econ. Dev.)

 

 

Voidable Transfers

Assets

Appellant commercial landlord challenged the summary-judgment dismissal of its claims to void a transfer of assets under the Minnesota Uniform Voidable Transactions Act (MUVTA) and for unjust enrichment. Appellant also challenged the District Court’s partial denial of its motion to compel discovery. The Court of Appeals concluded that the District Court properly granted summary judgment for respondent on appellant’s MUVTA claim because there was no genuine issue of material fact that the property transferred through a public foreclosure auction was encumbered by a valid lien and therefore not an “asset” subject to MUVTA. And the District Court did not abuse its discretion in its discovery rulings. But the District Court misapplied the law when it granted summary judgment for respondent on appellant’s unjust-enrichment claim. Affirmed in part, reversed in part, and remanded.

A25-0681 MOAC Hall Holdings, LLC v. Walking Co. (Hennepin County)

 

 

Zoning

Billboards

Appellant, billboard operator, challenged the District Court’s grant of summary judgment in favor of respondent-city in an appeal to the District Court related to respondent’s denials of appellant’s land-use application and respondent’s alleged violation of the Minnesota Open Meeting Law (OML). Respondent cross-appealed to challenge the standard used by the District Court to determine whether an email communication from the city attorney was protected by the attorney-client privilege. The Court of Appeals concluded that the District Court did not err in determining that appellant was not entitled to a sign permit as the proposed billboard violated the plain language of the ordinance, as it was within 300 feet of a place of worship abutting a right-of-way. However, the District Court erred in substituting the standard for closing a city council meeting under OML in place of the caselaw standard for the attorney-client privilege. Affirmed in part, reversed in part, and remanded.

A25-0802 ROA Rochester, LLC v. City of Rochester (Olmsted County)

 

 

Zoning

Delegation

Twenty years ago, a land developer and respondent city entered into a planned-use-development agreement that established a developer’s lot for specified commercial-use development and that protected the development from the effect of any future change in the city’s regulations, comprehensive plan, or official controls unless and until the city and developer agreed to amend the agreement. The city contemporaneously passed an ordinance approving the planned-use development, and the developer properly recorded the agreement and, over time, expended substantial funds to develop the land. When the developer recently sought to convey part of the land for use as a tire center, however, the city indicated that it preferred a different use (a restaurant), passed a moratorium on the development activity, and asked the District Court for a judgment declaring the official-control-protection provision to be void. The District Court granted summary judgment to the city, reasoning that the provision is void ab initio as an invalid delegation of the city’s zoning authority. Holding that Minnesota law allows a city to agree to protect city-approved planned developments from the effect of any later amendment to the city’s comprehensive plan or official controls for any period the city deems reasonable, the Court of Appeals concluded that the District Court erred in finding that the agreement to do so in this case constituted an unlawful delegation of the city’s authority. Reversed and remanded.

A25-1093 City of Oakdale v. Oakdale Marketplace, LLC (Washington County)

 

 

 

 

Criminal Nonprecedential

 

Arrest

Probable Cause

Defendant appealed from the judgment of conviction of two counts of second-degree sex trafficking, arguing that the District Court erred by denying his motion to suppress evidence that he argued was the fruit of an unlawful warrantless arrest for sex trafficking and evidence that was obtained from warranted searches of hotel rooms and cell phones because the search warrants were not supported by probable cause. Noting that the so-called informant was more properly considered a victim of the crime of sex trafficking than an informant, and that she reported her firsthand knowledge of sex trafficking, the Court of Appeals concluded that the totality of the circumstances justified defendant’s arrest. But the order to register as a predatory offender was incorrect. Affirmed in part, reversed in part, and remanded.

A25-0053 State v. Jones (Dakota County)

 

 

Criminal Sexual Conduct

Sufficiency of the Evidence

A jury found defendant guilty of first-degree criminal sexual conduct after it received evidence that he sexually penetrated a woman who had been intoxicated to the point of unconsciousness. Defendant appealed from his consequent conviction, arguing that the evidence was insufficient to support the guilty verdict. The Court of Appeals concluded that the evidence supports the finding that defendant knew or should have known about the victim’s helpless condition and the jury can determine guilt based on the testimony of a single witness. Affirmed.

A25-0275 State v. Stevens (Clearwater County)

 

Damage to Property

Probably Cause

The state appealed the dismissal for lack of probable cause of the charge brought against respondent juvenile for aiding and abetting first-degree criminal damage to property based on evidence the respondent and two others opened the hatch cover of a municipal water reservoir. The Court of Appeals concluded that the costs of isolating and testing the water for contamination could be included in calculating whether the amount of property damage to the water reservoir exceeded $1,000. Reversed and remanded.

A25-1324 In re Welfare of D.L.B. (Dakota County)

 

 

 

Driving Without a License

Sufficiency of the Evidence

Defendant challenged his convictions for driving with a revoked license and driving with expired registration, arguing that the evidence was insufficient to support the convictions and that there was no evidence to show that he was given notice of his license revocation. Noting that evidence of actual receipt of the revocation notice is not necessary to support a conviction, the Court of Appeals concluded that the evidence was sufficient to support defendant’s conviction for driving with a revoked license. Affirmed.

A25-0198 State v. Ryan (Ramsey County)

 

 

DWI

Enhancement

A driving-while-impaired (DWI) charge may be enhanced to a first-degree offense when a driver “commits the violation within ten years of the first of three or more qualified prior impaired driving incidents.” Defendant argued that the District Court erred in convicting him of the enhanced first-degree DWI offense because the state failed to present sufficient evidence to prove that he had three qualified driving incidents in the ten years preceding the underlying offense. Noting that judicial review of 2024 revocation of defendant’s license under the implied-consent law was pending at the time the District Court enhanced defendant’s offense, the Court of Appeals concluded that the District Court erred in relying on the revocation as a qualified prior impaired driving incident. Reversed and remanded.

A25-0720 State v. Terrill (Beltrami County)

 

 

Felony Murder

Vacation

Appellant challenged the District Court’s denial of his fifth preliminary application to vacate his conviction of aiding and abetting second-degree unintentional felony murder, which was filed under a session law that establishes a process for individuals convicted of aiding and abetting felony murder to petition the District Court for vacation of that conviction if certain conditions are met. The Court of Appeals concluded that the District Court abused its discretion in denying appellant’s fifth preliminary application based on its determination that he was a major participant in the underlying felony. Reversed and remanded.

A25-0626 Colbert v. State (Ramsey County)

 

 

Plea Withdrawal

Fair & Just

Defendant pleaded guilty to one count of second-degree criminal sexual conduct. Before sentencing, he moved to withdraw his guilty plea on the ground that withdrawal would be fair and just. The District Court denied the motion. Noting that the District Court’s order omitted any mention of defendant’s asserted reasons why plea withdrawal would be fair and just, the Court of Appeals concluded that the District Court erred by not giving due consideration to the reasons advanced by defendant in support of his motion. Reversed and remanded.

A25-0765 State v. Moen (Big Stone County)

 

 

Prosecutorial Misconduct

Plain Error

Defendant argued that several instances of prosecutorial misconduct deprived him of a fair trial on his convictions of first- and second-degree criminal sexual conduct. Defendant conceded that he did not object to any of these at trial. The Court of Appeals concluded that the prosecutor did not plainly err by disparaging defense counsel, by inadequately preparing victim’s father and victim to testify, by stating that the jury should disregard information elicited by defendant on cross-examination, by commenting on defendant’s failure to contradict witness testimony, or by referring to defendant’s “sexual fantasies.” And the prosecutor did not commit reversible plain error by vouching for victim’s credibility. Affirmed.

A24-1561 State v. Hassan (Stearns County)

 

 

Prosecutorial Misconduct

Plain Error

In this appeal from an order denying postconviction relief after a conviction for fourth-degree assault, petitioner argued that the District Court abused its discretion by rejecting his claims of prosecutorial misconduct, erroneous evidentiary rulings, and judicial bias. The Court of Appeals concluded that, because petitioner’s misconduct claim rests on speculation, petitioner did not meet his burden to show a Brady violation occurred. Affirmed.

A25-0932 Silva v. State (Chisago County)

 

 

Right to Jury Trial

Waiver

This case arises from defendant’s failure to apprise his supervising corrections agent of a change in address, which resulted in a conviction for failure to fulfill the requirements of predatory-offender registration. On appeal, defendant argued that the District Court (1) failed to adequately advise him of his right to a jury trial, rendering his waiver of that right invalid; and (2) erred when it concluded that he was ineligible for supervised release and must instead serve his entire 16-month sentence in custody. Noting that the fact that the District Court did not inform defendant of the number of jurors who would comprise the jury or that he could have participated in their selection was not determinative, the Court of Appeals concluded that the District Court advised defendant of his right to a jury trial in accordance with applicable caselaw and Minn. R. Crim. P. 26.01. However, because the phrase “full term of imprisonment” in Minn. Stat. § 243.166, subd. 5(e), does not preclude supervised release, the District Court erred when it concluded that defendant was not eligible for supervised release. Affirmed in part, reversed in part, and remanded.

A25-0357 State v. Rodriguez (Nobles County)

 

 

Sentencing

Upward Departures

A jury found defendant guilty of first-degree criminal sexual conduct based on evidence that he sexually assaulted a young teenage girl. Defendant challenged his sentence. The Court of Appeals concluded that the District Court erred by relying on the aggravating factor of particular vulnerability due to age as the victim’s age was incorporated into an element of the offense of which defendant was convicted. But defendant was not entitled to a downward dispositional sentencing departure. Affirmed in part, reversed in part, and remanded.

A25-0433 State v. Monterroso Merida (Cottonwood County)

 

 

Threats

Sufficiency of the Evidence

In this direct appeal from the judgment of conviction for domestic assault and threats of violence, defendant argued that his threats-of-violence conviction should be reversed for insufficient evidence. He also argued that he was entitled to a new trial because the District Court erred by admitting the victim’s testimonial hearsay statements at trial under the forfeiture-by-wrongdoing exception, asserting that the state failed to prove that he procured the victim’s unavailability. Noting that there was no evidence of defendant’s tone or conduct when he made the threat to the victim that “[h]is pretty little teeth will be gone,” and that the victim instead spoke in general terms of defendant’s threats, the Court of Appeals concluded that the evidence was insufficient to support the conviction for threats of violence. But the District Court did not err by admitting the victim’s testimonial hearsay statements. Affirmed in part, reversed in part, and remanded.

A25-0495 State v. Anderson (Mower County)

 

 

Criminal Order Opinions

 

Postconviction Relief

Evidentiary Hearings

In these consolidated postconviction appeals, the District Court summarily denied petitioner’s petitions for postconviction relief for two convictions for felony threats of violence. Petitioner argued that, in each order, the District Court abused its discretion by denying his petition without an evidentiary hearing. The Court of Appeals concluded that the record in each case conclusively showed that petitioner was not entitled to postconviction relief on the face of the petition. Affirmed.

A25-1145, A25-1146 Andersen v. State (Carver County)

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