Court of Appeals Digest: April 27, 2026

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Civil Precedential

Defamation

Anti-SLAPP

On appeal from the dismissal of her defamation claims, appellant, a licensed clinical social worker, challenged a District Court order granting respondents’ special motion for expedited relief under Minnesota Uniform Public Expression Protection Act (UPEPA) and a District Court order denying appellant’s motion for post-judgment relief. The Court of Appeals held that a statement in a report to a state licensing board that initiates an investigation constitutes a “communication in a . . . governmental proceeding” within the meaning of Minn Stat § section 554.08(b)(1), such that claims based on the statement may be subject to a special motion for expedited relief under UPEPA. Affirmed.

A25-1075 Anderson v. Anderson (Stearns County)

Civil Nonprecedential

Arbitration

Agreement

In this appeal from an order confirming an arbitration award and directing entry of judgment in favor of respondent telecommunications provider, pro se appellant argued that no valid contract existed requiring arbitration, that the arbitrator was biased, and that he was entitled to summary judgment based on respondent’s alleged failure to timely respond. Noting that appellant accepted services and devices under agreements that clearly incorporated arbitration provisions, the Court of Appeals held that the District Court did not err in concluding that valid contracts existed. The court further held that appellant failed to establish any statutory grounds to vacate the arbitration award and respondent did not default. Affirmed.

A25-1582 Dixon v. Comcast Corp. (Hennepin County)

Defamation

Pleading

Pro se appellant challenged the District Court’s dismissal of his defamation and civil-conspiracy claims arising from alleged false statements made during a political campaign. The Court of Appeals held that the District Court erred in concluding that appellant failed to plead the allegedly defamatory statements with sufficient specificity, determining that the complaint adequately identified the speakers, recipients, context, and substance of the statements to provide fair notice. The court further held that appellant sufficiently pleaded actual malice at the motion-to-dismiss stage, as allegations of knowledge and intent may be averred generally, and the District Court improperly required a heightened factual showing. Reversed and remanded.

A25-1209 Scheffler v. Franzen (Crow Wing County)

Domestic Relations

Settlement Agreements; Fraud

Appellant mother, who signed a release of claims relating to an arbitration award of certain expenses for the parties’ joint children, argued that the District Court abused its discretion by determining that she failed to demonstrate that the release must be vacated due to fraud. Noting that the release tracked the arbitration award—even though the award contained a scrivener’s error—and appellant had the opportunity to review and sign the agreement with counsel, the Court of Appeals concluded appellant failed to establish fraud. Affirmed.

A25-1160 Nagle v. Nagle (Hennepin County)

Education

Review

The parents of respondent-student brought an administrative complaint to respondent Minnesota Department of Education (MDE) against relator-school district for an alleged violation of the federal Individuals with Disabilities Education Act (IDEA). After MDE concluded that the district violated the IDEA, the district appealed the decision to this court. In an earlier decision, the Court of Appeals concluded that MDE acted arbitrarily in rendering its decision, and we reversed and remanded for further proceedings. The district here appealed MDE’s decision on remand, which reaffirmed that the district violated the IDEA. The district argued that MDE failed to follow this court’s remand directive; that MDE’s decision was arbitrary, unsupported by substantial evidence, or the product of an error of law; and that MDE failed to apply a two-year statute of limitations. The Court of Appeals held that MDE complied with the court’s prior remand instructions by conducting a more balanced investigation and adequately explaining its departure from a prior agency decision. The court further held that MDE’s determination that the parents genuinely disagreed with the district’s prior evaluation was supported by substantial evidence. Finally, the court concluded that the parents’ administrative complaint was timely under the one-year statute of limitations applicable to state complaints, not the two-year period governing due-process hearings. Affirmed.

A25-1336 In re Remand Decision File 24-170R (Minn. Dep’t of Educ.)

Environmental Law

Water-Discharge Permits

Relator challenged an administrative order requiring it to obtain a water-discharge permit for continued operation of a decades-old sewage system, arguing that the agency lacked authority because the system was lawful when constructed and that its subsequent compliance mooted the violations. The Court of Appeals held that the Minnesota Pollution Control Agency (MPCA) has statutory authority to require a permit for the continued operation of a disposal system under current law, concluding that the order was not an impermissible retroactive application because it regulated ongoing operation rather than past construction. The court further held that historical compliance and prior inspections did not limit the MPCA’s authority to enforce present permitting requirements. Finally, the court determined that relator’s claimed compliance with the order was not properly before the court because it was outside the administrative record and had not been addressed through agency proceedings. Affirmed.

A25-1450 In re Wermager Beach Util. Co. (Minn. Pollution Control Agency)

Homeowner Associations

Consent

After respondent homeowner association recorded and sought to close on a lien on his property, appellant filed a petition under Minn. Stat. § 514.99 to have the lien declared invalid. The District Court denied his petition. The Court of Appeals held that the District Court properly limited its analysis to whether the lien was a “nonconsensual common law lien,” concluding that the recorded declaration constituted a contractual basis for the lien and rendered it consensual. The court further held that the declaration, recorded before appellant purchased the property, was binding on him through constructive notice and provided sufficient authority for the association to impose assessment liens under common law. Finally, the court determined that the declaration did not expire under Minn. Stat. § 500.20, subd. 2a, because it fell within the statutory exception for instruments authorizing an association to hold common real estate for the benefit of members. Affirmed.

A25-1442 Reed v. Highlands of Edinburgh Sixth Assoc. (Hennepin County)

Municipalities

Recreational-Use Immunity

Respondent fell and was injured while skating at appellant-city’s ice rink. Respondent sued the city, alleging that the city’s negligent maintenance of the ice rink caused his fall. The city asserted recreational-use immunity under Minn. Stat. § 466.03, subd. 6e, in a motion for summary judgment. The District Court denied the city’s motion, concluding that fact issues existed as the trespasser exception to recreational-use immunity. Noting that actual, not constructive, knowledge of the alleged dangerous condition—a gap in the ice near Zamboni doors—was required and that evidence of post-incident observations, routine maintenance practices, and unrelated prior incidents was insufficient to establish such knowledge, the Court of Appeals concluded that respondent failed to present evidence creating a genuine issue of material fact that the city had actual knowledge of the alleged dangerous condition. And therefore, the trespasser exception did not apply. Reversed.

A25-1653 Fritz v. City of Rochester (Olmsted County)

Public Employment

Killed in Line of Duty

A 52-year-old lieutenant passed away while on a medical leave of absence from his employment with the sheriff’s office. Relator, the lieutenant’s sister, challenged the denial of public-safety-officer death benefits following the death, arguing that his fatal heart attack and drowning were caused by occupational stress and therefore qualified as “killed in the line of duty.” Noting that the statutory heart-attack provision in Minn. Stat. § 299A.41, subd. 3, governed such claims and required that the heart attack occur during, shortly after, or within 24 hours of qualifying on-duty stressful or strenuous activity, the Court of Appeals held that the statutory criteria were not satisfied. Affirmed.

A25-1549 In re Vnuk (Minn. Dep’t of Pub. Safety)

Trusts

Interpretation

Appellants challenged a District Court order interpreting their parents’ trust documents, arguing that the District Court improperly applied the amended terms of one parent’s trust to property interests held by another parent’s trust. The Court of Appeals held that the District Court erred in concluding that only one children’s trust existed, determining instead that each parent’s trust created its own children’s trust upon the surviving spouse’s death and that each trust retained its own assets. The court further held that the District Court improperly applied purchase-option provisions from one parent’s amended trust to property interests held by the other parent’s trust, concluding that each trust’s terms apply only to its own assets. Reversed and remanded.

A25-1392 In re Trust of Proulx (Polk County)

Unemployment Benefits

Employment Misconduct

Relator, in her position as manager, failed to track income and expenses and then failed to pay past-due sales-tax bills. She was fired by respondent employer. After a hearing, an unemployment-law judge (ULJ) determined that relator was discharged for employment misconduct, and the decision was affirmed after reconsideration. The Court of Appeals concluded that substantial evidence supported the ULJ’s findings that relator failed to adequately track income and expenses, failed to maintain records, and failed to timely pay sales taxes, all of which constituted negligent conduct, and that this conduct was a serious violation of the employer’s reasonable expectations. Affirmed.

A25-1365 Schlichting v. Am. Legion – St. Francis Post 622 (Dep’t of Emp’t & Econ. Dev.)

Civil Order Opinions

Domestic Relations

Dissolution; Enforcement

Appellant-wife challenged a post-dissolution order requiring her to complete retirement-account distributions, pay respondent-husband his share of tax refunds, satisfy tax-related liabilities, and pay conduct-based attorney fees. The Court of Appeals held that the District Court did not abuse its discretion in enforcing the dissolution judgment, concluding that the order requiring payment of $5,388.50 represented respondent’s equal share of tax refunds and did not modify the parties’ substantive rights. The court further held that directing appellant to pay outstanding tax liabilities was consistent with the judgment’s allocation of responsibility for penalties resulting from her untimely filings. Affirmed.

A24-1954 Vander Wiel v. Wahlgren (Ramsey County)

Criminal Nonprecedential

Arrest

Probable Cause

Defendant sought reversal of his convictions for first-degree sale of a controlled substance and fifth-degree possession of a controlled substance. He argued that the District Court erred in denying his motion to suppress evidence seized following a warrantless arrest and a subsequent warrantless search of his person. Noting that the officers observed what they believed to be a hand-to-hand transaction and knew defendant from previous narcotics cases, that the transaction occurred in a known open-air drug market; and that officers saw the other party to the transaction almost immediately use suspected narcotics, the Court of Appeals concluded that officers had probable cause to arrest defendant and conduct a search of his person incident to that arrest. Affirmed.

A25-0441 State v. Middlebrook (Hennepin County)

Arrest

Probable Cause

A jury found defendant guilty of three crimes based on evidence that he possessed fentanyl and methamphetamine and unlawfully possessed a firearm. Defendant argued he District Court erred in denying his motion to suppress evidence obtained from warrantless seizures and searches of his person and vehicle. The Court of Appeals held that officers had probable cause to believe defendant was engaged in drug sales before detaining the vehicle, based on surveillance observations of suspected hand-to-hand transactions and contemporaneous drug use by known users immediately after interacting with occupants of the vehicle. Affirmed.

A25-0840 State v. Ryan (Hennepin County)

Assault

Intent

A jury found defendant guilty of second-degree assault based on evidence that he injured a woman by firing a handgun. Noting that assault-harm is a general-intent offense requiring only proof that the defendant intended to commit the physical act—here, discharging the firearm—not that he intended to cause a particular result or harm the victim, the Court of Appeals concluded that the evidence—including multiple trigger pulls from a firearm not prone to accidental discharge and physical evidence of multiple shots—supported a reasonable inference that defendant intentionally fired the weapon and was inconsistent with any rational hypothesis of accidental discharge. And the prosecutor’s statements accurately reflected the governing law. Affirmed.

A25-0865 State v. Abelson (Martin County)

Burglary

Sufficiency of the Evidence

In this direct appeal from final judgments of conviction for first- and second-degree burglary, unlawful possession of a firearm, unlawful possession of ammunition, and fifth-degree drug possession, defendant argued, inter alia, that the District Court erred in denying his motion for judgment of acquittal after the state rested its case-in-chief because the evidence was insufficient to prove that he constructively possessed certain items relating to the underlying charges. The Court of Appeals concluded that the record established in the state’s case-in-chief was sufficient to present a factual question for the jury as to defendant’s constructive possession of the firearm, wrench, screwdriver, other tools, ammunition, and the methamphetamine in the glass pipe— pipe—all of the items the state needed to prove that defendant possessed to sustain his convictions. Affirmed.

A25-0663 State v. Klingelhoets (Meeker County)

Child Pornography

Sufficiency of the Evidence

Defendant challenged his convictions for possession of pornographic works involving a minor by a registered predatory offender, arguing insufficient evidence that the works depicted real minors, that he knew or had reason to know their content and character, and that he was a registered predatory offender at the time of the offense. Noting that the District Court’s observation of the images, defendant’s admissions, and the nature of the materials supported a reasonable inference that the depictions involved real minors and not AI-generated images, the Court of Appeals held that the evidence was sufficient on all elements. Affirmed.

A25-0726 State v. Sanko (Carlton County)

Evidence

Prior Consistent Statements

Defendant challenged his conviction of first-degree criminal sexual conduct, arguing, inter alia, that he was entitled to a new trial because the District Court committed prejudicial error by admitting statements the complainant made during a forensic interview that were not consistent with the complainant’s trial testimony. The Court of Appeals determined that the District Court abused its discretion by admitting the entire forensic interview as a prior consistent statement because it included allegations about specific events that were not described in her trial testimony and thus was not admissible under Minn. R. Evid. 801(d)(1)(B). The court declined to affirm on alternative grounds under the residual hearsay exception because that theory was not raised below and the record lacked necessary findings. Reversed and remanded.

A25-0972 State v. Honan (Dakota County)

False Reporting

Sufficiency of the Evidence

Defendant challenged his conviction of two counts of falsely reporting police misconduct, arguing that the evidence was insufficient because he did not know the reported police misconduct was false. The Court of Appeals held that the circumstances proved—including surveillance video contradicting defendant’s account, lack of any interaction between the officer and defendant’s children, defendant’s failure to raise the allegations during a contemporaneous parenting-time hearing, and the timing of his report following an unfavorable ruling—supported the inference that defendant knowingly made false allegations. Affirmed.

A25-0994 State v. Halling (Wright County)

Fleeing an Officer

Sufficiency of the Evidence

The state challenged the District Court’s order granting defendant’s post-verdict motion for a judgment of acquittal for felony fleeing a peace officer. The state argued that the District Court erred by concluding that the state failed to prove beyond a reasonable doubt that defendant was given a signal to stop by a peace officer. The Court of Appeals held that the circumstances proved—including the officer’s activation of emergency lights, defendant’s awareness of the marked squad car, his act of looking back and accelerating, failure to stop, and subsequent concealment—supported the inference that a signal to stop was given and that defendant fled. Affirmed.

A25-0839 State v. Olson (Dakota County)

Hearsay

Public-Records Exception

Defendant appealed his convictions following a jury trial for seven counts of violating a domestic-abuse no-contact order (DANCO). He argued the District Court abused its discretion in admitting a register of actions (ROA) as evidence that he was served with the DANCO because the ROA is hearsay, not reliable, and violates his constitutional right to confront witnesses. The Court of Appeals held that the ROA was properly admitted under the public-records exception to the hearsay rule and did not violate the Confrontation Clause because the document was non-testimonial. Affirmed.

A25-1059 State v. Speten (Anoka County)

Ineffective Assistance of Counsel

Prejudice

While defendant awaited trial on three counts of criminal sexual conduct for twice assaulting his estranged wife, his attorney obtained three pretrial examination reports from two experts to opine as to mental-health issues bearing on defendant’s competency to stand trial and the viability of a mental-illness defense. Defendant was deemed competent to proceed with no ground on which to assert the defense. After the jury found him guilty as charged and the District Court entered a judgment of conviction, defendant unsuccessfully petitioned the District Court for postconviction relief on the theory that his attorney provided ineffective assistance of counsel by failing to investigate his brain-injury history, failing to call brain-injury witnesses to testify, and failing to conduct practice sessions to help defendant decide whether to testify. Noting that defendant conceded through counsel that the record contained no evidence that he would have pleaded guilty, the Court of Appeals concluded that defendant failed to establish that any of the alleged deficiencies in his attorney’s performance prejudiced his defense. Affirmed.

A24-0369 State v. McCarty (Dakota County)

Jurors

Batson Challenges

Defendant sought reversal of his convictions for third-degree criminal sexual conduct and felony domestic assault, arguing that the District Court (1) clearly erred by overruling his objection to the state’s peremptory challenge to a prospective juror of color; (2) abused its discretion by allowing a detective to offer expert testimony about the typical behaviors of victims of domestic violence; and (3) abused its discretion by permitting a witness to testify about a prior statement the victim made about defendant raping her. Noting that the mere removal of a minority juror without additional circumstances does not raise an inference of discriminatory intent, the Court of Appeals concluded that the District Court did not clearly err in determining that defendant failed to make a prima facie showing that the state’s peremptory challenge to the juror was racially discriminatory. Affirmed.

A25-0752 State v. Jones (Hennepin County)

Miranda

Custodial Interrogation

A jury convicted defendant of second-degree criminal sexual conduct after hearing witness testimony from the minor victim about defendant’s abuse. Defendant appealed his conviction, arguing that the District Court erred in admitting statements he made to a child-protection investigator after invoking his right to counsel. The Court of Appeals held that the investigator’s jailhouse interview constituted custodial interrogation under Miranda because she acted as an arm of the state, coordinating with law enforcement and eliciting incriminating responses relevant to the criminal investigation. Reversed and remanded.

A25-0798 State v. Flores (Dakota County)

Plea Withdrawal

Fair & Just

In this direct appeal, defendant argued that the District Court abused its discretion by denying his motion to withdraw his guilty plea to threats of violence prior to sentencing under the fair-and-just standard. He also argued that his plea was not constitutionally valid. The Court of Appeals held that the District Court did not abuse its discretion because it reasonably rejected defendant’s claims of anxiety, medication effects, and duress, finding his testimony not credible and concluding that his request reflected a change of mind rather than a valid basis for withdrawal. Affirmed.

A25-1088 State v. Bryant (Steele County)

Postconviction Relief

Newly Discovered Evidence

This was an appeal from a District Court’s order summarily denying pro se petitioner’s petition for postconviction relief. Petitioner argued that the District Court abused its discretion by: (1) improperly determining that his claim that a witness testified falsely failed under the applicable standard; (2) improperly determining that his claims that the state elicited false testimony and failed to disclose exculpatory evidence are procedurally barred; and (3) relying on the challenged testimony, which unlawfully resulted in prejudice as to the sentence appellant received. The Court of Appeals held that the District Court did not abuse its discretion in denying relief because, although some allegations of falsity were assumed true, petitioner failed to show that the jury might have reached a different result given substantial independent evidence of guilt. Furthermore, petitioner’s claims were barred by Knaffla and petitioner forfeited his sentencing argument. Affirmed.

A25-1069 Seeman v. State (Rice County)

Probation Revocation

Intentional Violations

Defendant challenged the District Court’s revocation of probation, arguing that the record did not support the determination that the need for confinement outweighed the policies favoring probation. The Court of Appeals held that the District Court did not abuse its discretion, concluding that the record supported the finding that defendant’s violations— including failure to complete sex-offender treatment, failure to maintain contact with probation, and use of prohibited materials—were intentional and that confinement was warranted. Affirmed.

A25-1382 State v. Johnson (Hubbard County)

Sentencing

Criminal History Score

In this direct appeal from a conviction for aiding and abetting the importation of controlled substances across state borders, defendant argued that the District Court abused its discretion in denying downward dispositional and durational departures and erred in calculating his criminal-history score. The Court of Appeals concluded that the state failed to meet its burden to establish defendant’s criminal-history score where it relied solely on a presentence investigation report that did not adequately demonstrate sentencing on prior out-of-state convictions. However, there was no error in denying the departure motions. Affirmed in part, reversed in part, and remanded.

A25-1775 State v. Evans (Hennepin County)

Sentencing

Downward Departures

Defendant pleaded guilty to second-degree unintentional murder. At sentencing, the District Court granted defendant a downward durational departure from the presumptive sentence on the grounds that he was remorseful and that his offense was significantly less serious than the typical offense of its kind based on a comparison of the circumstances in his case to the elements of second-degree manslaughter. The state appealed, arguing that the District Court abused its discretion by relying on improper grounds for departure and in the length of its departure. Emphasizing that defendant intended to shoot to scare rather than to hit a person and acted in response to a perceived threat following prior break-ins, the Court of Appeals concluded that the District Court properly determined that defendant’s offense was significantly less serious than a typical second-degree unintentional murder based on a comparison to second-degree manslaughter. Affirmed.

A25-1850 Cain v. State (Hennepin County)

Sentencing

Downward Departures

Defendant challenged his sentence for unlawful possession of a firearm by a felon convicted of a crime of violence, arguing that the District Court abused its discretion in denying his motion for a downward dispositional departure and by not granting a downward durational departure sua sponte. Noting that the District Court carefully evaluated the relevant factors, including defendant’s criminal history, amenability to probation, and the Trog factors, and reasonably determined that defendant was not particularly amenable to probation, the Court of Appeals found no abuse of discretion. And a District Court is not required to consider a sua sponte durational departure. Affirmed.

A25-0997 State v. Jones (Rice County)

Sentencing

Downward Departures

Defendant pleaded guilty to domestic assault. He moved for a downward dispositional departure from the presumptive sentencing range. The District Court denied the motion and imposed an executed sentence of 32 months of imprisonment. Noting that the District Court considered defendant’s extensive criminal history, lack of remorse, inconsistent statements, and conduct at sentencing, the Court of Appeals concluded that the District Court did not err by denying the motion. Affirmed.

A25-1264 State v. Thompson (Carlton County)

Sentencing

Downward Departures

In this sentencing appeal, defendant argued that he was deprived of his constitutional right to an impartial judge when the District Court conducted independent research while deciding defendant’s motion for a downward dispositional departure on his convictions for first-degree drug sale and fourth-degree driving while impaired. The Court of Appeals held that the District Court did not engage in an impermissible independent investigation of facts in evidence because an email from an MNTC employee was unrelated to the evidentiary record and was referenced only in response to counsel’s general argument about public scrutiny of sentencing decisions. Affirmed.

A25-1165 State v. Truelove (Le Sueur County)

Sentencing

Predatory Offender Registration

Defendant challenged the requirement that he register as a predatory offender based on a kidnapping charge that he was acquitted of by a jury, arguing that the District Court erred by determining that the acquitted charges and convicted charge arose out of the same circumstances or, in the alternative, that the predatory-offender registration requirement based on acquitted conduct was unconstitutional. Noting that the registration statute applies where a defendant is charged with an enumerated offense and convicted of another offense arising from the same circumstances, even if acquitted of the enumerated offense, and that the assault and kidnapping charges were sufficiently linked in time, place, participants, and events, the Court of Appeals concluded that the kidnapping charge was supported by probable cause and that the registration statute is a civil, regulatory measure that does not violate the Sixth Amendment or due process. Affirmed.

A25-0934 State v. Nickens (Dakota County)

Criminal Order Opinions

Postconviction Relief

Evidentiary Hearing

Petitioner appealed the postconviction court’s denial of his petition for relief from his conviction of fifth-degree criminal sexual conduct, arguing he was entitled to an evidentiary hearing. Noting that a petitioner must provide more than conclusory or argumentative assertions and must identify material facts to be established at a hearing, the Court of Appeals held that the postconviction court did not abuse its discretion in denying the petition without a hearing because appellant failed to allege specific facts that, if proven, would entitle him to relief. Affirmed.

A25-1434 Gishe v. State (Ramsey County)