Supreme Court Digest: April 1, 2026

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Civil

Attorney Discipline

Reinstatement

In April 2023, petitioner Herbert A. Igbanugo was indefinitely suspended from the practice of law with no right to petition for reinstatement for 10 months. Igbanugo petitioned for reinstatement in July 2024. A unanimous panel of the Lawyers Professional Responsibility Board recommended against reinstatement, concluding that Igbanugo had failed to prove by clear and convincing evidence that he had undergone the requisite moral change. Igbanugo contested the panel’s findings, conclusions, and recommendation, and he asserted that he should be reinstated. The Director of the Office of Lawyers Professional Responsibility agreed with the panel’s recommendation to deny reinstatement.

The Supreme Court held that, based on its independent review of the record, the Lawyers Professional Responsibility Board panel’s conclusion that petitioner had not met his burden of proving moral change to practice law, as required for reinstatement, was not clearly erroneous. Petition denied.

A24-1103 In re Igbanugo (Original Jurisdiction)

Attorney Discipline

Suspension

The Director of the Office of Lawyers Professional Responsibility petitioned for disciplinary action against respondent-attorney Herbert A. Igbanugo, alleging that he violated Minnesota Rules of Professional Conduct 3.1, 4.4(a), and 8.4(d).2 The alleged misconduct arose from a lawsuit that Igbanugo filed in the United States District Court for Minnesota, which the district court dismissed as frivolous and for which Igbanugo was sanctioned. After an evidentiary hearing, the referee in this disciplinary proceeding found that Igbanugo’s lawsuit was frivolous; that his conduct related to the lawsuit violated Rules 3.1, 4.4(a), and 8.4(d); and that he should be suspended from the practice of law for 12 months. The Director did not contest the referee’s findings or conclusions and supported the referee’s discipline recommendation. Igbanugo also did not challenge the referee’s findings or conclusions, but he contested the recommended discipline.

The Supreme Court held that (1) the referee’s finding that the attorney committed misconduct by filing a frivolous lawsuit was not clearly erroneous; and (2) an indefinite suspension with no right to petition for reinstatement for 12 months is the appropriate discipline for the attorney’s misconduct. Suspended.

A24-1119 In re Igbanugo (Original Jurisdiction)

Criminal

Judges

Partiality

The question in this appeal from the postconviction court’s summary denial of petitioner’s postconviction petition was whether the judge at his jury trial for first-degree murder was impartial. Noting that conducting legal research on issues and arguments the parties raise before making decisions does not render a judge partial, the Supreme Court held that the district court did not abuse its discretion by summarily denying petitioner’s postconviction petition alleging that the judge at his jury trial was not impartial. Affirmed.

A25-1274 Glover v. State (Ramsey County)

Right to Counsel

Substitute Counsel

A jury found defendant guilty of first-degree premeditated murder, second-degree intentional murder, and ineligible possession of a firearm. The district court convicted defendant and sentenced him to life imprisonment without the possibility of release on the first-degree premeditated murder charge. In this direct appeal, defendant argued that the district court abused its discretion when it denied his request for substitute appointed counsel. Defendant claimed that the district court did not conduct a “searching inquiry” sufficient to determine whether exceptional circumstances—circumstances affecting appointed counsel’s ability or competence to represent defendant—existed. Defendant further claimed that the district court abused its discretion when it accepted defendant’s waiver of the right to counsel. Defendant raised multiple other claims in a pro se supplemental brief.

The Supreme Court held that (1) the district court conducted a “searching inquiry” into the allegations underlying defendant’s request for substitute counsel when the district court’s inquiry, combined with its knowledge of the record, provided sufficient information to allow the district court to determine the truth and scope of the defendant’s allegations and whether the allegations presented exceptional circumstances calling into question the attorney’s ability and competence to represent the defendant; (2) the district court did not err when it determined that the defendant’s waiver of counsel was constitutionally valid; and (3) the claims raised in appellant’s pro se supplemental brief lacked merit. Affirmed

A24-0952 State v. Tillman (Ramsey County)