Court of Appeals Digest: May 26, 2026

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Civil Precedential

Landlord & Tenant

Eviction

Appellant tenant challenged an eviction judgment for nonpayment of rent, arguing that the District Court lacked subject-matter jurisdiction and erred by entering judgment for recovery of the premises because she never possessed the apartment and never acquired a legal right to possess it. The Court of Appeals held that an eviction action seeking judgment for recovery of the premises requires that the defendant be in actual possession of the premises or hold a present legal right to possess the premises sought to be recovered. The court concluded that the District Court had subject-matter jurisdiction over the eviction action because Minnesota District Courts possess statutory authority to hear eviction proceedings and tenant’s possession defense did not defeat jurisdiction. Applying general contract principles, the court concluded that the lease agreement contained an unambiguous condition precedent requiring payment of the security deposit before any legal right to possession transferred to tenant. Because tenant never paid the security deposit, never received access to the apartment, and never physically occupied the premises, landlord failed to establish the possessory interest necessary to support an eviction judgment. Reversed.

A25-1728 Hegenes Props., LLC v. Rodriguez (Rice County)

Civil Nonprecedential

Arbitration

Judgment

Property owner challenged a District Court order confirming an arbitration award arising from a construction-payment dispute, arguing that the arbitrator exceeded his authority by awarding pre-award interest and that the prevailing contractor was barred from later seeking attorney fees under the mechanic’s lien statute after arbitration concluded. The Court of Appeals held that the arbitrator acted within the scope of his authority because the parties’ arbitration agreement incorporated American Arbitration Association rules expressly authorizing arbitrators to award interest. The court further held that the arbitration award precluded the contractor from later seeking attorney fees in District Court because the contractor had expressly requested attorney fees during arbitration, and the arbitrator’s final award stated that all claims and requests for relief not awarded were denied. The court concluded that the District Court therefore erred by permitting post-arbitration litigation of mechanic’s-lien attorney fees, though uncontested post-award attorney fees remained recoverable on remand. Affirmed in part, reversed in part, and remanded.

A25-1734 Advanced Eng’g & Env’t Servs., LLC v. Gaughan Cos. (Scott County)

Civil Commitment

Mental Illness; Sufficiency of the Evidence

Appellant challenged his indeterminate commitment as mentally ill and dangerous, arguing that he did not suffer from a mental illness, that the county presented false information, and that he received ineffective assistance of counsel. The Court of Appeals held that clear and convincing evidence—including testimony from two court-appointed examiners and extensive medical and commitment records—supported the District Court’s findings that appellant suffered from a substantial psychiatric disorder and posed a substantial likelihood of physical harm to others. The court further held that appellant failed to substantiate his claims regarding false evidence or ineffective assistance of counsel and failed to demonstrate resulting prejudice. Affirmed.

A25-1943 In re Civ. Commitment of Sailee (Hennepin County)

Domestic Relations

Child Protection; Termination of Parental Rights

Mother challenged the termination of her parental rights to her minor child, arguing that the county failed to make reasonable reunification efforts and that termination was unsupported and contrary to the child’s best interests. The Court of Appeals held that substantial evidence supported multiple statutory grounds for termination, including mother’s inability to consistently meet the child’s significant medical needs despite extensive county assistance and treatment services. The court further held that the county made reasonable reunification efforts and that the child’s substantial improvement in foster care supported the District Court’s best-interests determination. The court also concluded that mother’s challenge to the denial of her motion to vacate the default termination order was not properly before the court. Affirmed.

A25-1671 In re Welfare of Child(ren) of B.N. (St. Louis County)

Domestic Relations

Dissolution; Antenuptial Agreements

Appellant wife challenged the validity and enforceability of the parties’ antenuptial agreement and the District Court’s resulting property award in a marital-dissolution proceeding between a real-estate developer husband and wife, who left her career to raise the parties’ four children during a lengthy marriage. The Court of Appeals held that the antenuptial agreement was procedurally fair under both common law and Minn. Stat. § 519.11 because husband made a full and fair disclosure of his substantial assets before marriage, wife had an opportunity to consult with independent counsel of her choice, and the agreement was not procured through duress, undue influence, or abuse of fiduciary relations. The court further held that the agreement was supported by adequate consideration because wife was entitled to substantial spousal-maintenance payments and a mortgage-free home in the event of dissolution. The court additionally concluded that the agreement was substantively fair both when executed and when enforced because the parties contemplated significant future increases in husband’s wealth and the agreement did not leave wife without meaningful financial support. Affirmed.

A25-0534 Johannson v. Johannson (Hennepin County)

Domestic Relations

Parenting Time; Education

Appellant mother challenged an amended dissolution judgment determining that the parties’ joint child would primarily reside and attend school in Minnesota with father after beginning kindergarten, arguing that the District Court improperly reconsidered its earlier findings, abused its discretion regarding parenting-time determinations, unfairly managed the trial, and demonstrated judicial bias. The Court of Appeals held that the District Court acted within its discretion in granting father’s motion for amended findings because the court was permitted to reexamine the evidence and amend interconnected findings after reviewing the record as a whole. The court further held that the District Court adequately addressed the parties’ remaining posttrial motions, reasonably interpreted and structured the parenting-time schedule to approximate equal parenting time, and did not abuse its discretion in requiring mother to exercise portions of her parenting time in Minnesota or in weighing the child’s sibling relationship against the importance of preserving the child’s relationship with father. Affirmed.

A25-0455 Zweber v. Zweber (Dakota County)

Election Law

Single Subject

Health-insurance entities challenged a 2024 omnibus law under the Minnesota Constitution’s Single-Subject Clause, arguing that the law improperly combined numerous unrelated subjects into a single enactment. The Court of Appeals held that the entities’ challenge to provisions regarding employee misclassification was nonjusticiable because they failed to demonstrate a concrete or imminent injury sufficient to establish standing or ripeness. As to provisions restricting state contracting with for-profit health maintenance organizations, the court held that the challenge was justiciable but failed on the merits under controlling Minnesota Supreme Court precedent. The court concluded that the challenged provisions were germane to the law’s stated subject concerning the operation and financing of state government and therefore did not violate the Single-Subject Clause, despite the omnibus law’s broad range of topics. Affirmed.

A25-1398 UnitedHealth Group Inc. v. State (Ramsey County)

Employment Law

Retaliatory Discharge

Former employee challenged summary judgment dismissing claims for retaliatory discharge under the Minnesota Whistleblower Act and Minnesota Workers’ Compensation Act, arguing that the District Court improperly applied the McDonnell Douglas burden-shifting framework and that genuine issues of material fact existed regarding whether the employer’s stated reasons for discharge were pretextual. The Court of Appeals held that the employee forfeited any challenge to application of the McDonnell Douglas framework by relying on that framework in District Court and, in any event, Minnesota precedent expressly authorizes its use in retaliation cases at summary judgment. Applying that framework, the court further held that the employee failed to present evidence creating a genuine issue of material fact that the employer’s stated reasons for discharge—violation of workplace recording policies and insubordination—were false or motivated by retaliation for protected conduct. The court concluded that the employee’s assertions of retaliatory motive rested on speculation rather than evidence sufficient to survive summary judgment. Affirmed.

A25-1785 Garcia v. Daikin Applied Ams. Inc. (Hennepin County)

Extreme Risk Protection Orders

Constitutionality

Pro se appellant challenged a one-year extension of an extreme risk protection order (ERPO), arguing that the ERPO statutes violated the First, Second, and Fourteenth Amendments; that the District Court erred by relying on findings and evidence from the original ERPO proceeding; that the District Court lacked authority to extend the ERPO after the original order expired; and that the petitioning police department lacked authority to seek the extension. The Court of Appeals held that appellant’s constitutional challenges were not properly preserved because he failed to timely notify the Minnesota Attorney General and failed to develop an adequate district-court record for appellate review. The court further held that appellant could not collaterally attack the validity of the original ERPO in an appeal from the extension order because he failed to directly appeal the original ERPO when entered. The court also concluded that the District Court acted within its statutory authority by orally extending the existing ERPO while the extension request was under advisement and issuing the written extension order the following day, despite expiration of the original order in the interim. Finally, the court held that the police department was authorized under the ERPO statutes to apply for the extension regardless of appellant’s claimed change of residence. Affirmed.

A25-1605 City of Blaine Police Dep’t v. Luedtke (Anoka County)

Harassment Restraining Orders

Harassment

Pro se appellant challenged the denial of his petition for a harassment restraining order (HRO), arguing that respondent’s conduct during a Rotary Club meeting constituted harassment and that his anxiety disorder made him particularly vulnerable under an “eggshell plaintiff” theory. The Court of Appeals held that the District Court did not abuse its discretion because the record established only a single incident and therefore failed to satisfy the statutory requirement of repeated intrusive or unwanted acts necessary to support an HRO. The court further held that the eggshell-plaintiff doctrine does not apply in the HRO context because the doctrine concerns the scope of tort damages rather than whether conduct satisfies the statutory definition of harassment, which is evaluated under an objective standard. Affirmed.

A25-1841 Marhula v. Eaton (Beltrami County)

Insurance

Fire Coverage

Insureds challenged summary judgment in favor of their insurers following denial of coverage for fire damage to a workshop structure, arguing that the policy should be reformed to comply with Minnesota’s standard fire-policy statute, that the policy language failed to clearly exclude fire coverage, and that the insurer negligently undervalued the property. The Court of Appeals held that Minn. Stat. § 65A.01 does not require every insurance policy to provide fire coverage and therefore did not require reformation of the policy where the declarations expressly excluded fire and lightning coverage for the structure. The court further held that the policy language unambiguously excluded fire coverage and that the insureds’ own testimony established they understood before purchasing the policy that no fire coverage applied to the structure. Finally, the court held that dismissal of the negligence claim was proper because valuation of property for insurance purposes required expert testimony regarding the applicable standard of care, which the insureds failed to provide. Affirmed.

A25-1694 Harner v. FBL Fin. Servs., Inc. (Rice County)

Unemployment Benefits

Employment Misconduct

Pro se relator challenged a determination that he was ineligible for unemployment benefits after being discharged for repeated absences from scheduled shifts without advance notice. The Court of Appeals held that the unemployment-law judge (ULJ) adequately developed the record by questioning witnesses, admitting exhibits, and continuing the hearing to allow relator an opportunity to submit additional evidence. The court further held that the ULJ did not err in concluding that relator committed employment misconduct because the employer maintained a reasonable attendance-and-notification policy, relator knew of the policy, and relator repeatedly violated it. Finally, the court held that substantial evidence supported the ULJ’s findings and credibility determinations regarding relator’s attendance record and failure to provide notice for absences. Affirmed.

A25-1701 Wilson v. Jerry’s Enters., Inc. (Dep’t of Emp’t & Econ. Dev.)

Civil Order Opinions

Landlord & Tenant

Attorney Fees

Tenant challenged the District Court’s denial of attorney fees following a partially successful rent-escrow action involving alleged habitability violations and repair issues. The Court of Appeals held that tenant forfeited her statutory-interpretation argument that attorney fees were mandatory under Minn. Stat. § 504B.172 because she failed to raise that argument in District Court. The court further held that remand was necessary because the District Court failed to explain the basis for denying attorney fees and did not determine which party, if either, was the prevailing party where both sides achieved partial success. Remanded.

A25-1417 Curd v. Lambert (Hennepin County)

Criminal Precedential

Predatory Offender Registration

Mens Rea

Defendant challenged his conviction for failing to register as a predatory offender, arguing that the state failed to prove he knowingly violated the registration statute. The Court of Appeals held that the state did not prove beyond a reasonable doubt that defendant knowingly failed to register as a predatory offender by providing an address that was both his workplace address and his secondary address without specifying that the address was his secondary address. The court reasoned that, although defendant provided the restaurant address on registration forms as his employment address and evidence established that he also regularly stayed there overnight, the statute did not expressly require a registrant to list the same address multiple times or separately specify every applicable statutory category. Reversed.

A25-0785 State v. Heggs (Mower County)

Criminal Nonprecedential

Criminal Sexual Conduct

Coercion

Defendant challenged his conviction and sentence for third-degree criminal sexual conduct, arguing that the evidence was insufficient to prove coercion, that the District Court incorrectly calculated his criminal-history score, and that his waiver of counsel was invalid because he was misinformed about his sentencing exposure. The Court of Appeals held that sufficient evidence supported the jury’s finding of coercion because the victim testified that defendant created an atmosphere of fear that left her feeling unable to resist or leave, and corroborating DNA evidence and defendant’s inconsistent statements supported the verdict. The court further held that remand was required for resentencing because the District Court had not determined whether two prior convictions arose from the same behavioral incident and therefore should have counted separately in defendant’s criminal-history score. Finally, the court held that defendant knowingly, intelligently, and voluntarily waived counsel despite uncertainty regarding the precise criminal-history score because he understood the nature of the charges, the possibility of a lengthy prison sentence, and repeatedly insisted on proceeding pro se after extensive warnings from the District Court. Affirmed in part, reversed in part, and remanded.

A25-1151 State v. Powell (Hennepin County)

Distributing Sexual Material to Minor

Mistake of Age

Defendant challenged his convictions of solicitation of a child through electronic communication and distribution of sexual material to a child through electronic communication, arguing that the District Court abused its discretion by refusing to allow a mistake-of-age defense and related jury instruction. The Court of Appeals held that the District Court properly determined that the defense was unavailable because defendant had prior in-person contact with the minor before the electronic communications occurred. Affirmed.

A25-1340 State v. Klimek (Otter Tail County)

Evidence

Alternative Perpetrators

Defendant challenged his conviction and sentence for first-degree criminal sexual conduct, arguing that the District Court improperly excluded alternative-perpetrator evidence and applied the wrong legal standard when denying his motion for a downward durational departure. The Court of Appeals held that the District Court acted within its discretion by excluding the proposed alternative-perpetrator evidence because defendant failed to present evidence inherently tending to connect the proposed alternative perpetrator to the charged conduct. The court concluded that evidence showing only that the proposed perpetrator may have been present in the home and generally matched portions of a witness description was insufficient to satisfy the foundational requirements for admission of alternative-perpetrator evidence. However, the court further held that the District Court abused its discretion at sentencing by relying on offender-related factors and a particular-amenability-to-probation analysis, which apply to dispositional departures rather than downward durational departures. Affirmed in part, reversed in part, and remanded.

A25-1087 State v. Edberg (Stearns County)

Evidence

Prior Sexual Conduct

Defendant challenged his conviction for third-degree criminal sexual conduct, arguing that the District Court violated his constitutional right to present a complete defense by excluding evidence that the complainant had allegedly made a prior false accusation of sexual assault during earlier domestic proceedings involving another partner. The Court of Appeals held that the District Court did not abuse its discretion by excluding the evidence under Minnesota’s rape-shield rule and Minn. R. Evid. 403. The court concluded that the alleged prior accusation had limited probative value because the circumstances differed substantially from the present case, while the proposed testimony risked unfair prejudice, juror confusion, and a distracting “trial within a trial” concerning unrelated relationship disputes. The court further held that the alleged prior accusation did not establish a sufficiently similar common scheme or plan relevant to consent under Minn. R. Evid. 412 because the purported motives and surrounding circumstances materially differed. Affirmed.

A25-1113 State v. Nelson (Hennepin County)

Evidence

Prior Sexual Conduct

Defendant challenged his conviction for first-degree criminal sexual conduct, arguing that the District Court improperly excluded evidence relating to the victim’s prior foster-care abuse, improperly withheld confidential records following in camera review. The Court of Appeals held that the District Court did not abuse its discretion by excluding evidence of the victim’s prior abuse because the evidence fell within the protections of Minnesota’s rape-shield law and carried a substantial risk of unfair prejudice and juror speculation that outweighed any limited probative value. The court further held that exclusion of the evidence did not violate defendant’s constitutional right to present a complete defense because defendant remained free to present his theory that the victim had a motive to fabricate allegations based on concerns about child-protection involvement. After independently reviewing the confidential records in camera, the court also concluded that the District Court properly withheld undisclosed materials because they were not relevant, material, or favorable to the defense. Affirmed.

A25-1006 State v. Strong (St. Louis County)

Hearsay

State of Mind

Juvenile appellant challenged a delinquency adjudication for third-degree criminal sexual conduct, arguing that the District Court improperly sustained a hearsay objection, that counsel provided ineffective assistance in presenting a mistake-of-age defense, and that lengthy pretrial delays violated his constitutional right to a speedy trial. The Court of Appeals held that the challenged statement about the victim telling someone she was 18 was inadmissible hearsay and did not qualify under the state-of-mind exception because it was not contemporaneous with the asserted belief and was made under circumstances suggesting a motive to misrepresent. The court further held that appellant failed to establish ineffective assistance because counsel’s failure to contest the hearsay objection was not objectively unreasonable and appellant did not demonstrate prejudice from any alleged investigative shortcomings. Finally, the court held that although the approximately one-year delay before trial was presumptively prejudicial, the delays were largely attributable to witness unavailability and court scheduling, appellant never demanded a speedy trial, and he failed to show legally cognizable prejudice. Affirmed.

A25-1499 In re Welfare of K.A.L.T.D. (Stearns County)

Ineffective Assistance of Counsel

Deficient Performance

Defendant challenged his convictions for disseminating child sexual abuse materials, arguing that his trial counsel provided ineffective assistance by failing to subject the state’s case to meaningful adversarial testing, thereby constituting structural error. The Court of Appeals held that counsel’s performance did not amount to the complete failure required to establish structural error. The court concluded that counsel meaningfully participated throughout the proceedings by reviewing extensive discovery, negotiating a favorable proposed plea agreement, preparing plea materials, advising defendant regarding a stipulated-facts trial, and advocating for concurrent sentences at sentencing. The court further held that defendant failed to identify any viable suppression motions, favorable evidence omitted from the stipulated facts, or alternative defense strategy that counsel unreasonably failed to pursue. Affirmed.

A25-1061 State v. Phillippi (Hubbard County)

Jurors

Batson Challenges

Defendant challenged his first-degree criminal-sexual-conduct conviction, arguing that the District Court improperly denied his Batson challenge after the state used a peremptory strike against the only Hispanic prospective juror, and further challenged the imposition of a lifetime conditional-release term. The Court of Appeals held that, although the District Court did not strictly follow the prescribed Batson procedure by hearing the prosecutor’s explanations before determining whether a prima facie case existed, the record did not establish purposeful racial discrimination. The court concluded that the prosecutor offered a race-neutral explanation based on the juror’s limited responsiveness during voir dire and that the record did not show disparate treatment of similarly situated non-Hispanic jurors. However, the District Court erred by imposing a lifetime conditional-release term because defendant had no prior sex-offense convictions. Affirmed in part, reversed in part, and remanded.

A25-0462 State v. Escamilla (Wright County)

Jury Instructions

Unanimity

A jury found defendant guilty of first-, second-, and third-degree criminal sexual conduct based on evidence that he abused his stepdaughter almost daily throughout most of her childhood, including incidents in Wisconsin and Florida. On appeal, defendant argued that the District Court plainly erred by failing to issue a unanimity instruction on various elements of these charges, admitting evidence of incidents outside Minnesota over which it lacked jurisdiction, and failing to instruct the jury that the state must prove that any sexual contact occurred when his stepdaughter was younger than 13 as it related to the first-degree charge. He also maintained that the District Court erroneously both executed his sentence and imposed probationary terms. The Court of Appeals held that the District Court did not plainly err by failing to issue an unanimity instruction on count one based on Minn. Stat. § 609.342, subd. 1(h)(iii), as the state sought to prove a single incident of sexual abuse by offering examples of that abuse over a reasonable period of time and the defense relied on denying the abuse allegations generally rather than specifically. The court also concluded that the state had jurisdiction over defendant’s abusive acts in Florida and Wisconsin as part of two offenses with their Minnesota origin, and the instructions were not erroneous as Minn. Stat. § 609.342 does not link the age requirement of sexual contact in subdivision 1 to the “sexual abuse” language in paragraph (h)(iii). However, defendant’s sentencing challenge did identify an error. Affirmed in part, reversed in part, and remanded.

A25-0554 State v. Montes Banegas (Chisago County)

Postconviction Relief

Knaffla Bar

Petitioner challenged the denial of postconviction relief from his conviction for third-degree criminal sexual conduct without an evidentiary hearing, arguing that his claims of ineffective assistance of counsel and an invalid guilty plea were not procedurally. The Court of Appeals held that appellant’s claims were barred under Knaffla because the same ineffective-assistance and plea-validity arguments had already been raised and rejected on direct appeal. Affirmed.

A25-1641 Schober v. State (Carver County)

Public Trial

Findings

Defendant challenged his convictions for first-degree criminal sexual conduct following a court trial, arguing that the District Court violated his constitutional right to a public trial by excluding spectators from portions of the proceedings without making the findings required. The Court of Appeals held that the District Court erred by closing the courtroom during witness testimony and the playing of recorded interview evidence without conducting an evidentiary hearing or making specific findings addressing the required Waller factors, including whether closure was necessary, narrowly tailored, and supported by consideration of reasonable alternatives. The court concluded that the appropriate remedy was not immediate reversal for a new trial, but remand for an evidentiary hearing at which the state would have an opportunity to justify the closure. The court directed that, if the District Court determines the closure was constitutionally justified, the convictions may stand, but if the closure was unjustified or overly broad, the convictions must be vacated and a new trial granted. Affirmed in part, reversed in part, and remanded.

A25-0867 State v. Monson (Aitkin County)

Right to Counsel

Substitute Counsel

Defendant challenged convictions for controlled-substance possession and test refusal, arguing that the District Court failed to adequately address her request for substitute counsel, that law enforcement violated her right to counsel before chemical testing, and that trial counsel was ineffective. The Court of Appeals held that defendant’s vague statement about counsel lacking confidence did not amount to the serious allegations necessary to require a searching inquiry or substitute counsel. The court further held that defendant forfeited her right-to-counsel claim by failing to raise it during omnibus proceedings and that Minnesota precedent foreclosed the argument in any event. Finally, the court concluded that defendant forfeited her ineffective-assistance claim by inadequately briefing it. Affirmed.

A25-1190 State v. Crumble (Hennepin County)

Self-Defense

Evidence

Defendant challenged his third-degree assault conviction arising from a domestic altercation with his girlfriend, arguing that the District Court improperly excluded portions of a recorded phone call and limited testimony regarding prior violent incidents involving the victim. The Court of Appeals held that the excluded portions of the recording constituted inadmissible hearsay because defendant had not testified about those specific incidents at trial, preventing the statements from qualifying as prior consistent statements. The court further held that the District Court acted within its by excluding evidence of specific prior acts due to the risk of unfair prejudice and juror confusion. The court rejected defendant’s claim that the ruling violated his right to present a complete defense. Affirmed.

A25-0691 State v. Meat (Beltrami County)

Sentencing

Downward Departures

Defendant challenged the District Court’s denial of his motion for a downward dispositional departure from his conviction for first-degree criminal sexual conduct, arguing that he was particularly amenable to probation based on factors including his limited criminal history, remorse, cooperation, treatment participation, and community support. The Court of Appeals held that the District Court did not abuse its discretion by imposing the presumptive executed sentence, noting that the existence of mitigating factors does not obligate a District Court to grant probation or depart from a presumptive sentence. Affirmed.

A25-0873 State v. Johnson (Roseau County)

Sentencing

Restitution

Defendant challenged a restitution order entered after sentencing for felony theft, arguing that the District Court lacked authority to impose restitution after sentencing because the victims’ losses were already known and that the court failed to consider his ability to pay. The Court of Appeals held that defendant forfeited his challenge to the District Court’s authority to order restitution after sentencing by failing to raise that specific objection before the District Court. The court further held that the District Court failed to comply with Minn. Stat. § 611A.045 because it neither orally nor in writing expressly considered defendant’s income, resources, and obligations before ordering restitution. Affirmed in part, reversed in part, and remanded.

A25-1724 State v. Crabtree (Becker County)

Speedy Trial

Reason for Delay

Defendant challenged his second-degree-assault and drive-by-shooting convictions, arguing that the District Court violated the Uniform Mandatory Disposition of Detainers Act (UMDDA) and his constitutional right to a speedy trial by delaying trial beyond the applicable statutory period, and further erred by admitting a police sergeant’s testimony identifying him in surveillance footage. The Court of Appeals held that the District Court did not err in finding good cause for a continuance under the UMDDA based on the unavailability of the state’s lead investigator due to military leave. The court further held that the District Court satisfied the UMDDA’s requirement that good cause be shown “in open court” because the state presented its basis for the continuance during a hearing with defendant and counsel present, even though the court later issued its ruling in a written order. The court also concluded that defendant’s constitutional speedy-trial right was not violated because, despite the lengthy delay and defendant’s repeated speedy-trial demands, defendant failed to demonstrate actual prejudice to his ability to present a defense. Finally, the court held that the District Court did not abuse its discretion by admitting the sergeant’s testimony regarding surveillance footage because the testimony was rationally based on the sergeant’s observations and defendant’s own admissions during an interview. Affirmed.

A25-0942 State v. Ramsey (Hennepin County)

Traffic Stops

Traffic Violations

Defendant challenged convictions for fleeing a peace officer in a motor vehicle and impaired driving, arguing that the District Court erred by denying his motion to suppress evidence obtained during a traffic stop because the deputy lacked reasonable, articulable suspicion to stop his vehicle. The Court of Appeals held that the District Court did not clearly err by crediting the deputy’s testimony that defendant failed to come to a complete stop at a stop sign before entering an intersection, despite defendant’s argument that squad-car video footage contradicted the testimony. Affirmed.

A25-0630 State v. Wurzbacher (McLeod County)

Criminal Order Opinions

Felony Murder

Aiding & Abetting

Appellant challenged the summary denial of his petition for relief from his conviction for aiding and abetting second-degree felony murder under the 2023 felony-murder-relief act, arguing that the District Court improperly resolved disputed material facts and made credibility determinations without an evidentiary hearing. The Court of Appeals held that reversal and remand were required because the record contained conflicting evidence regarding appellant’s role in the underlying offense, including contradictory statements concerning who supplied the murder weapon, creating a material factual dispute bearing on whether appellant was a major participant. The court further held that the District Court erred by making credibility determinations without first conducting an evidentiary hearing, consistent with recent precedent prohibiting credibility determinations in these proceedings absent a hearing. Reversed and remanded.

A25-1661 Scott v. State (Anoka County)