Court of Appeals Digest: March 23, 2026

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Civil Nonprecedential

Drivers’ License Revocation

Extension

Pro se petitioner challenged the District Court’s denial of his petition to review the extension of his license-revocation period. Noting that statutory amendments permitting judicial review of extensions of license-revocation periods apply only to crimes committed after August 1, 2025, and the petitioner challenged his 2024 extension, the Court of Appeals concluded that the District Court properly dismissed the petition for lack of subject-matter jurisdiction. Affirmed.

A25-0878 Ingebrigtsen v. Comm’r of Pub. Safety (Goodhue County)

Harassment Restraining Orders

Due Process

Pro se appellant argued that the District Court abused its discretion in granting two harassment restraining orders (HROs) against him by (1) violating his procedural-due-process rights; (2) making findings unsupported by the record; (3) violating his free-speech constitutional rights; (4) fashioning geographic restrictions; and (5) denying his rule 60.02 motions. The Court of Appeals concluded that the District Court did not violate appellant’s due-process rights or otherwise err. Affirmed.

A25-1601, A25-1602 Ambrose v. Nettifee (Lincoln County)

Municipalities

General Sales Taxes

Appellant challenged the District Court’s grant of summary judgment in favor of respondent-city on appellant’s claim that the City of St. Paul unlawfully disbursed public funds to city projects that were not specifically included in the city’s resolution regarding entitlement to the funds. The Court of Appeals concluded that the District Court erred by concluding that a session law broadened the scope of the projects on which the city could use the revenue to include parks that were not listed within an attachment to the resolution. Reversed and remanded.

A25-1380 Butler v. City of St. Paul (Ramsey County)

New Trial

Cumulative Impact

This matter arose from a dispute between appellant-purchaser and respondents, seller and a ranch, concerning the purchase of a horse. Appellant alleged that respondent defrauded appellant and breached a contract between them after respondent delivered a lame horse. Respondent and her husband counterclaimed for defamation and defamation per se arising from a Facebook post by appellant about the dispute. The jury returned a verdict for respondent. On appeal, appellant argued that the District Court abused its discretion by denying her motion for a new trial based on what she alleged were irregularities occurring before and during trial. The Court of Appeals was not convinced that any irregularity occurred and discerned no prejudicial error or abuse of discretion by the District Court. Affirmed.

A25-1169 Larsen v. Mullen (Olmsted County)

Real Property

Negligent Misrepresentation

In this appeal arising from a dispute over a real estate sale and numerous defects in the property, appellant homeowner challenged the District Court’s order granting summary judgment in favor of respondents, seller’s real estate agent and the real estate brokerage firm. The Court of Appeals concluded that no genuine issues of material fact preclude summary judgment as to certain negligent misrepresentation and fraud claims. But genuine issues of material fact precluded summary judgment on other negligent misrepresentation, fraud, breach of contract, and promissory estoppel claims. Affirmed in part, reversed in part, and remanded.

A25-1068 Zhong v. Dudero (Dakota County)

Civil Order Opinions

Summary Judgment

Pro Se Parties

Appellant challenged a District Court order granting summary judgment in favor of respondent and awarding respondent attorney fees and costs on appellant’s claims for harassment, assault, and defamation. Appellant argued that he was entitled to reversal because he was unable to provide evidentiary support due to a lack of legal expertise and legal resources. The Court of Appeals concluded that appellant failed to identify a legally sufficient basis to reverse the District Court’s grant of summary judgment. Affirmed.

A25-0608 Renslow v. Schultz (Hennepin County)

Criminal Nonprecedential

Bail Bonds

Reinstatement

Appellant surety challenged the District Court’s partial denial of its petition to reinstate and discharge a forfeited bail bond, arguing that the District Court abused its discretion in weighing the factors regarding reinstatement. Noting the finding that appellant did not locate or return defendant and did not voluntarily pay the penalty for failing to ensure his presence, the Court of Appeals concluded that, because the record supported the District Court’s determination that three factors weighed against reinstatement—one heavily so—and the fourth was neutral, the District Court did not abuse its discretion by reinstating half of the bond amount. Affirmed.

A25-1627 State v. Bruce (Stearns County)

Plea Withdrawal

Voluntariness

In this direct appeal, defendant challenged the constitutional validity of his guilty plea to charges including possession of a firearm by an ineligible person. Defendant also argued that correction of his warrant of commitment was required. Noting that the state fulfilled its promise when it recommended to the District Court that defendant remain out of custody following his guilty plea, and that record showed that defendant understood he needed to comply with the conditions of his release to remain out of custody pending sentencing, the Court of Appeals concluded that the state did not breach the plea agreement and defendant entered a voluntary and accurate guilty plea. However, the warrant of commitment incorrectly included a conviction for unlawful possession of ammunition. Reversed and remanded.

A25-0549 State v. Clay (Redwood County)

Postconviction Relief

Time Bar

Petitioner challenged the postconviction court’s denial of her petition for postconviction relief from her 2012 conviction for second-degree assault and other crimes. Petitioner argued that the physical-disability and newly-discovered-evidence exceptions to the time bar applied. The Court of Appeals concluded that petitioner failed to demonstrate that her health concerns prevented her from timely filing a petition for postconviction relief, and the newly-discovered-evidence exception did not apply. Affirmed.

A25-0890 State v. Treptow (Anoka County)

Right to Complete Defense

Alternative Perpetrators

In this appeal from convictions for first-degree criminal sexual conduct following a jury trial, at issue was whether the District Court abused its discretion when it denied defendant’s motion to introduce alternative-perpetrator evidence related to his brother, who was the victim’s father. The jury found defendant guilty as charged of three incidents of sexual penetration of his niece, a child under 13. Noting that, while the allegations made by the victim’s  sisters about what father did to them were similar to what defendant was alleged to have done to the victim, this does not inherently tend to connect father to the commission of this charged offense against the victim in this matter, the Court of Appeals concluded that the District Court appropriately rejected defendant’s proposed alternative-perpetrator evidence and correctly imposed three sentences. But the 648-month sentence exaggerates his criminality; his sentence should not exceed 504 months. Affirmed in part, reversed in part, and remanded.

A24-1040 State v. Rakowiecki (Isanti County)

Sentencing

Restitution

In this sentencing appeal, which followed a stay and remand for postconviction proceedings, defendant argued that the District Court abused its discretion by overruling his objection to the state’s submission of its restitution request 46 days beyond the expiration of the District Court’s 30-day deadline when neither the state nor the victim offered any explanation for its tardiness. The Court of Appeals discerned no abuse of discretion. Affirmed.

A25-0474 State v. Freeman (Hennepin County)

Criminal Order Opinions

Appeals

Guilty Pleas

Defendant pleaded guilty to a charge of violating an ignition-interlock restriction. He argued on appeal that the District Court erred in a pre-trial evidentiary ruling. Noting that defendant did not challenged the validity of his guilty plea, the Court of Appeals concluded that waived his right to challenge the District Court’s order. Appeal dismissed.

A25-1038 State v. Stoll (Itasca County)