Court of Appeals Digest: June 15, 2026

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Civil Nonprecedential

Domestic Relations

Child Protection; CHIPS

Father appealed a CHIPS adjudication involving his 12-year-old son, arguing that the county failed to prove a statutory basis for the adjudication and that the disposition was not in the child’s best interests. The Court of Appeals held that clear and convincing evidence supported the District Court’s determination that the child was without proper parental care because of the parent’s emotional or mental condition and resulting inability to provide care. The court relied on evidence that father had relapsed into methamphetamine use, exhibited paranoid and potentially suicidal behavior, failed to make appropriate arrangements for the child’s care before incarceration, and ultimately became unavailable to care for the child due to a prison sentence. The court concluded that these circumstances supported a finding that the child lacked proper parental care and required protection or services. The court further held that the District Court adequately explained why the CHIPS disposition served the child’s best interests, citing testimony from the social worker and guardian ad litem, the lack of suitable alternative placements identified by father, and father’s inability to provide appropriate care. Affirmed.

A26-0041 In re Welfare of Child(ren) of D.L.S. (Stearns County)

Dometic Relations

Dissolution; Marital Property

Husband appealed multiple aspects of a dissolution judgment, challenging the valuation and division of a cabin property, the award and security of spousal maintenance, the distribution of marital assets and liabilities, conduct-based attorney fees, and a firearm restriction. The Court of Appeals held that the District Court did not clearly err in valuing the cabin property using its tax-assessed value, in determining that only the parties’ $50,000 payment toward acquiring an additional ownership interest constituted marital property, or in rejecting husband’s claimed improvements based on credibility and evidentiary deficiencies. The court further held that the District Court adequately considered the statutory maintenance factors and acted within its discretion by requiring a portion of husband’s property-sale proceeds to be escrowed as security for maintenance payments. The court also affirmed the overall division of assets and liabilities and upheld an award of post-decree conduct-based attorney fees based on husband’s unsuccessful motion for amended findings. However, the court concluded that the District Court’s award of $25,000 in pre-decree conduct-based attorney fees was unsupported because several findings lacked evidentiary support. Finally, the court rejected husband’s Second Amendment challenge, construing the firearm restriction as a limited-duration condition related to custody and parenting-time concerns. Affirmed in part, reversed in part, and remanded.

A25-1030 Patterson v. Patterson (Anoka County)

Domestic Relations

Spousal Maintenance; Modification

Wife appealed an order modifying spousal maintenance to $0 per month, reserving future maintenance, and making the modification retroactive to the date of husband’s motion. The Court of Appeals held that the District Court did not clearly err in calculating husband’s gross income by excluding speculative trust interests because the record supported the finding that husband had never received trust distributions and there was no evidence of periodic trust income. The court further held that the District Court did not abuse its discretion by declining to impute potential income to husband, where husband’s loss of employment was involuntary, the record supported the finding that he had made substantial efforts to obtain comparable employment, and the District Court found no bad-faith underemployment or unjustifiable self-limitation of income. Finally, the court held that the District Court acted within its discretion by making the maintenance modification retroactive to the date husband served his motion, as authorized by statute. Affirmed.

A25-1331 Stwalley v. Stwalley (Hennepin County)

Drivers’ License Revocation

Traffic Stops

Driver appealed the denial of his petition to reinstate his driver’s license following an implied-consent revocation, arguing that police lacked reasonable, articulable suspicion to stop his vehicle because the information came from anonymous 911 callers. The Court of Appeals held that the stop was lawful. The court concluded that the callers were sufficiently reliable because they used the 911 system, contemporaneously reported firsthand observations of a driver slumped over at traffic lights, and provided details about the vehicle, location, direction of travel, and license plate information. Officers corroborated key aspects of the reports by locating a matching white pickup truck in the reported area and confirming that its license plate closely matched the reported number. Affirmed.

A25-1597 Hines v. Comm’r of Pub. Safety (Hennepin County)

Injunctions

Success on the Merits

Medical providers, counties, sheriffs, and the Minnesota Sheriffs’ Association appealed the denial of a temporary injunction against enforcement of recently enacted Minn. Stat. § 241.021, subd. 4f, which generally requires correctional facilities to continue medications prescribed to incarcerated persons before confinement. The Court of Appeals held that the District Court did not abuse its discretion in denying temporary injunctive relief under the Dahlberg factors. The court concluded that appellants were unlikely to succeed on the merits because their constitutional and statutory challenges were not presently justiciable. The alleged harms depended on a chain of hypothetical future events, including conflicts between medical judgment and statutory requirements, and no enforcement action had yet been taken against any appellant. The court further held that the balance of harms favored the commissioner because enjoining enforcement would interfere with legislative policy choices, correctional-facility oversight, and continuity of inmate medical care. The court also determined that public-policy considerations favored allowing the statute to take effect pending resolution of the merits, while emphasizing that it expressed no opinion regarding the ultimate validity of the statute. Affirmed.

A25-1685 Advanced Corr. Healthcare, Inc. v. Schnell (Ramsey County)

Manufactured Homes

Eviction

A manufactured-home-park owner that leased lots to tenants under agreements that promised to provide sewage service “at no charge” began increasing rents and imposing sewage fees after the City of Oronoco connected the park to its new municipal sewer system and began charging for its use. The park owner commenced suits to evict tenants who refused to pay its new fees. The District Court denied the owner’s eviction claims and awarded the tenants attorney fees. The Court of Appeals held that the District Court acted within its discretion in determining that the sewage fees constituted an unenforceable substantial modification of the parties’ lease agreements. The leases promised sewage service “at no charge,” and the new fixed and usage-based sewer fees imposed a significant new expense on residents while eliminating a material landlord obligation. The court rejected the park owner’s argument that changed circumstances justified the modification, concluding that the District Court was not required to analyze statutory factors concerning changed circumstances and resident benefits, and that the owner had forfeited certain arguments by failing to seek amended findings. The court further held that the tenants were the prevailing parties because they successfully defeated the eviction actions and prevented collection of the disputed sewer fees, notwithstanding that some escrowed rent funds were ultimately awarded to the landlord.. Affirmed.

A25-1751 Oronoco Estates MHC Owner LLC v. Gregory (Olmsted County)

Medical Malpractice

Expert Affidavits

Trustee for a deceased child appealed the dismissal of medical-malpractice claims and the grant of summary judgment on a claim under the Emergency Medical Treatment and Labor Act (EMTALA). The Court of Appeals held that the District Court abused its discretion by dismissing the medical-malpractice claims under Minn. Stat. § 145.682. The court concluded that the expert reports sufficiently identified the applicable standard of care, the alleged breaches, and an outline of causation by explaining that medical providers failed to report suspected medical neglect when a critically ill child was removed from the emergency department against medical advice, resulting in the child not receiving lifesaving treatment. The court determined that the District Court improperly required a level of detail regarding law-enforcement intervention and timing that exceeded the expert-disclosure requirements. The court separately held that summary judgment was properly granted on the EMTALA claim because the hospital offered treatment, informed the child’s father that refusal of treatment could result in death, and took reasonable steps to obtain written acknowledgment of the refusal before the child was removed from the hospital against medical advice. Affirmed in part, reversed in part, and remanded.

A25-1548 Pitchford v. Hunter (Olmsted County)

Probate

Elective Shares

Surviving spouse appealed the dismissal of her petition for an elective share of the decedent’s augmented estate, arguing that the District Court should have allowed her to withdraw or amend admissions deemed admitted after she failed to timely respond to requests for admission concerning ownership of a joint bank account. The Court of Appeals held that the District Court acted within its discretion by treating the requests as admitted under Minn. R. Civ. P. 36.01 because the spouse did not respond within 30 days and never filed a motion under Rule 36.02 to withdraw or amend the admissions. The court further held that the admissions conclusively established that, upon the decedent’s death, ownership of the account passed entirely to the decedent’s son and daughter-in-law. Affirmed.

A25-1554 In re Estate of Sorenson (Nobles County)

Public Employment

Duty Disability Benefits

Police officer sought review of PERA’s denial of duty-disability benefits after sustaining a traumatic brain injury during a canine explosive-detection training exercise. PERA granted regular disability benefits but concluded that the officer was not performing an inherently dangerous duty when injured because she was loading suitcases into a trailer during cleanup rather than actively handling explosives. The Court of Appeals held that PERA’s decision was not supported by substantial evidence. The court concluded that PERA improperly isolated one component of the training exercise and treated it as a stand-alone duty, despite undisputed evidence that cleanup, accounting for explosive training aids, and securing them in the bunker were integral parts of a single required training exercise. The court further determined that the training exercise as a whole was inherently dangerous because it involved live explosive materials and duties specific to law-enforcement explosive-detection work. Reversed.

A25-1668 In re PERA Police & Fire Plan Disability Application of Stoler (Pub. Emps. Ret. Assoc.)

Real Property

Adverse Possession

Property owners claimed ownership by adverse possession of a backslope adjacent to their driveway and argued that the District Court improperly dismissed their related lateral-support claim. The Court of Appeals held that the District Court did not treat the lateral-support ruling as dispositive of the adverse-possession claim; rather, it dismissed the lateral-support claim because the adverse-possession claim failed. On the merits, the court concluded that appellants failed to establish a genuine issue of material fact on the hostility element of adverse possession. Evidence that appellants mowed the backslope, sprayed weeds, filled holes, and were the only persons maintaining the area demonstrated occasional maintenance but did not show possession of the property as owners to the exclusion of others. The court further rejected appellants’ argument that agricultural-property adverse-possession principles required a different result, concluding that the cited precedent did not establish a separate hostility standard. Because appellants failed to present evidence from which a reasonable factfinder could find hostile possession for the statutory period, summary judgment was proper. Affirmed.

A25-1115 Berkner Living Trust v. Kotten (Brown County)

Real Property

Easements

Property owners appealed summary judgment determining that a township’s utility easement extended across their entire property, including a disputed portion of a vacated roadway. The Court of Appeals held that the District Court misinterpreted the easement agreement. Applying ordinary principles of contract interpretation and Minn. Stat. § 507.17, the court concluded that the easement’s legal description unambiguously extended only to two lots and a specifically described portion of a vacated roadway. Although the law generally presumes that a conveyance of property abutting a vacated roadway includes the roadway, the court held that the easement agreement expressed a contrary intent by precisely describing only one identified portion of the roadway and excluding the disputed remainder. Reversed.

A25-1550 Gelao v. Zumbro Twp. (Wabasha County)

Unemployment Benefits

Quit

Relator challenged a determination that she was ineligible for unemployment benefits, arguing that her separation from employment was effectively caused by workplace conditions and pressure from her employer. The Court of Appeals held that substantial evidence supported the unemployment-law judge’s finding that relator voluntarily quit her employment as part of a negotiated workers’ compensation settlement agreement. The court deferred to the ULJ’s credibility determinations rejecting relator’s claim that she resigned because of employer pressure or anticipated termination. The court further concluded that relator did not establish a constructive discharge because she never received notice of termination and chose to separate while employment remained available. Because the record supported the finding that relator resigned to obtain the settlement and not for a statutory exception to disqualification, she was ineligible for unemployment benefits. Affirmed.

A25-1470 Coyne v. Dollar Gen. (Dep’t of Emp’t & Econ. Dev.)

Zoning

Interim-Use Permits

Property owner appealed the dismissal of mandamus and declaratory-judgment claims after a township denied his application for an interim-use permit to operate a contractor’s yard. The Court of Appeals first held that the appeal was not moot despite a post-judgment amendment to the township’s zoning ordinance because the township failed to establish from the record that the amended ordinance would independently bar the proposed use. On the merits, the court held that the township substantially complied with the notice-extension provisions of Minn. Stat. § 15.99 when it mailed an extension notice containing a minor addressing error, and therefore the application was not approved by operation of law. The court further concluded that, even if the statutory timeline had not been properly extended, the township lacked authority to approve the application because the proposed contractor’s yard and related structures failed to satisfy the zoning ordinance’s 250-foot setback requirement. Since a governmental body cannot be compelled to approve a use that violates its zoning ordinance, the township did not fail to perform a duty clearly imposed by law. Affirmed.

A25-1897 Hansen v. Haven Twp. (Sherburne County)

Civil Order Opinions

Account Stated

Summary Judgment

Debtor appealed summary judgment entered in favor of an assignee of a consumer debt, arguing that genuine issues of material fact existed regarding ownership of the debt, that the assignee was acting as an unauthorized debt collector, and that the District Court failed to address her motion for sanctions. The Court of Appeals held that summary judgment was proper on the assignee’s account-stated claim. The court concluded that the record established the debtor-creditor relationship, the amount owed, and the assignee’s ownership of the debt through documentary evidence, including a bill of sale transferring the account. Affirmed.

A25-1766 LVNV Funding LLC v. Spradley (Washington County)

Orders for Protection

Mootness

Appellant challenged District Court orders denying his motions to vacate an order for protection (OFP) and denying reconsideration. The Court of Appeals held that the appeal was moot because the OFP expired by its own terms before appellate review was completed. Appeal dismissed.

A25-1981 Henry v. Lewis (Hennepin County)

Zoning

Variances

Property owner appealed the dismissal of claims challenging a city’s denial of an after-the-fact variance application. The Court of Appeals held that the action was untimely because the applicable Orono zoning ordinance required any judicial challenge to a zoning decision to be commenced and served within 30 days of the decision, and appellant did not serve the city until more than a year after the variance denial. Affirmed.

A25-0891 Taunton v. City of Orono (Hennepin County)

Criminal Nonprecedential

Controlled Substance Crimes

Amelioration

The State appealed a postconviction order vacating petitioner’s conviction for first-degree controlled-substance possession after the legislature amended Minn. Stat. § 152.021 to effectively decriminalize possession of controlled substances dissolved in the fluid of a water pipe. The Court of Appeals held that the postconviction court properly applied Minnesota’s amelioration doctrine. The court concluded that the amendment mitigated punishment and that the legislature did not clearly express an intent to abrogate the amelioration doctrine. Although the amendment included an effective-date provision stating that it applied retroactively from August 1, 2023, the provision did not limit application to offenses committed on or after a specified date, unlike other statutes that Minnesota courts have held clearly abrogate the doctrine. The court further noted that the legislature used explicit prospective-only language in other sections of the same enactment, indicating that its omission from the amendment at issue was intentional. Affirmed.

A25-1636 State v. Hollingsworth (Pipestone County)

Criminal Sexual Conduct

Sufficiency of the Evidence

Defendant appealed his conviction for fourth-degree criminal sexual conduct arising from a massage therapist’s nonconsensual touching of a client’s breasts and nipples, arguing that the evidence was insufficient to prove sexual intent, that inadmissible evidence was admitted, that the prosecutor committed misconduct, that the jury instructions were inadequate, and that cumulative error deprived him of a fair trial. The Court of Appeals held that the circumstantial evidence was sufficient to establish sexual intent because defendant intentionally touched the complainant’s bare breasts and nipples without consent or any therapeutic justification, leaving no reasonable inference other than sexual gratification. The court further held that defendant failed to establish reversible evidentiary error regarding testimony about text messages, and that although the prosecutor committed limited misconduct by suggesting that believing the complainant was sufficient to convict and by disparaging the defense, the misconduct did not warrant reversal because it did not affect the fairness or outcome of the trial. Affirmed.

A25-0916 State v. Barrow (Hennepin County)

Criminal Sexual Conduct

Sufficiency of the Evidence

Defendant appealed his convictions for two counts of first-degree criminal sexual conduct, arguing that the evidence was insufficient because the case rested primarily on the testimony of the complainant—his stepdaughter—without corroboration. The Court of Appeals held that the witness’s testimony constituted direct evidence and that a conviction may rest on the uncorroborated testimony of a single credible witness absent unusual circumstances calling the witness’s credibility into question. The court concluded that the record revealed no significant inconsistencies, credibility concerns, or other circumstances requiring corroboration. Affirmed.

A25-1322 State v. Bibiano (Sibley County)

Ineffective Assistance of Counsel

Deficient Performance

Petitioner appealed the denial of postconviction relief from charges including attempted second-degree murder, arguing that appellate counsel was ineffective for failing to challenge a clerical error in a jury verdict form and for failing to raise claims of prosecutorial misconduct on direct appeal. The Court of Appeals held that appellate counsel’s performance did not fall below an objective standard of reasonableness. The court concluded that the verdict-form issue lacked merit because the record consistently reflected that petitioner was charged, tried, instructed, convicted, and sentenced for attempted second-degree murder, and the omission of the word “attempted” from the verdict form was a clerical error later corrected by the District Court. Affirmed.

A25-1575 Banks v. State (Hennepin County)

Ineffective Assistance of Counsel

Prejudice

Defendant appealed convictions for identity theft and unlawful possession of a firearm, arguing that counsel was ineffective for failing to argue for a downward dispositional departure at sentencing. The Court of Appeals held that defendant could not establish prejudice because there was no reasonable probability that the outcome would have been different had counsel made the argument. Affirmed.

A25-1308 State v. Harris (Ramsey County)

Ineffective Assistance of Counsel

Prejudice

Defendant appealed his convictions for attempted second-degree criminal sexual conduct, second-degree assault, and fifth-degree assault, arguing that he received ineffective assistance of counsel when trial counsel failed to seek a writ of prohibition after the District Court denied his notice to remove the assigned judge, that prosecutorial misconduct during closing argument deprived him of a fair trial, and that he was entitled to additional custody credit for time spent on electronic home monitoring. The Court of Appeals held that defendant’s direct challenge to the denial of his notice to remove was forfeited because he failed to seek a writ of prohibition. The court further held that defendant could not establish prejudice on his ineffective-assistance claim because the notice to remove was untimely and a writ petition would not have succeeded. The court also concluded that, although the prosecutor improperly disparaged defense counsel during closing argument, the misconduct was limited and did not affect defendant’s substantial rights in light of the strength of the evidence. Finally, the court held that electronic home monitoring does not constitute custody for purposes of jail credit. Affirmed.

A24-1694 State v. Love (Redwood County)

Plea Withdrawal

Accuracy

Petitioner appealed the denial of postconviction relief, arguing that he should be permitted to withdraw his guilty plea to third-degree criminal sexual conduct because the factual basis did not establish the coercion element of the offense. The Court of Appeals held that the plea was accurate and therefore valid. The court concluded that petitioner expressly admitted during the plea colloquy that he coerced the victim to engage in the sexual act and further admitted facts satisfying the statutory definition of coercion. Affirmed.

A25-1803 Pomavilla Pomabilla v. State (Anoka County)

Plea Withdrawal

Adequate Factual Basis

Defendant appealed a conviction entered on an Alford plea and the sentence imposed for aiding an offender after the fact. The Court of Appeals held that the plea was valid because the record established a strong factual basis supporting a finding that defendant intentionally provided false or misleading information during a homicide investigation and that a jury would likely find defendant guilty despite her claim of innocence. The court further held that the District Court abused its discretion in assigning a severity level of eight to the unranked offense. Affirmed in part, reversed in part, and remanded.

A25-1407 State v. Holmgren (Beltrami County)

Probation Revocation

Expiration

Defendant appealed the revocation of his probation and execution of a stayed prison sentence for first-degree driving while impaired., arguing that his probation expired by operation of law under Minnesota’s 2023 probation-reform legislation before the District Court purported to extend it. The Court of Appeals held that the District Court lacked authority to revoke probation in 2025 because defendant’s probationary term expired on October 1, 2023. The court concluded that the 2023 legislation imposed a retroactive five-year cap on most felony probation terms and required any extension for unpaid restitution to be ordered before the October 1, 2023 expiration date. Although defendant had outstanding restitution obligations, the District Court did not conduct the required extension hearing or order an extension until October 4, 2023, after probation had already expired by operation of law. The court further held that defendant’s failure to appear at an earlier hearing did not create an exception to the statutory expiration date and that the District Court never initiated probation-revocation proceedings under the separate statutory procedures available for violations occurring before probation expired. Reversed and remanded.

A25-1742 State v. Tollefson (Clearwater County)

Seizure

Consent

Juvenile appealed the denial of a motion to suppress a firearm discovered during a pat-frisk, arguing that police unlawfully seized him before observing conduct giving rise to reasonable suspicion. The Court of Appeals held that the officers’ initial contact with the parked vehicle was a consensual encounter rather than a seizure. The court concluded that two uniformed officers merely approached the vehicle, asked general questions, used flashlights for visibility, and did not activate emergency lights, display weapons, physically restrain occupants, block the vehicle’s movement, or issue commands indicating compliance was required. Because a reasonable person would have felt free to terminate the encounter, no seizure occurred before an officer observed appellant holding a cannabis cigarette. That observation supplied reasonable, articulable suspicion of criminal activity, and appellant did not challenge the validity of the subsequent pat-frisk. Affirmed.

A25-1749 In re Welfare of P.K.T. (Hennepin County)

Sentencing

Custody Credit

The State appealed a resentencing order awarding defendant 424 days of custody credit after a prior appellate remand directing recalculation of jail credit under established interjurisdictional-custody principles. While the appeal was pending, defendant’s sentence expired and he moved to dismiss the appeal as moot. The Court of Appeals held that, once a sentence expires, a District Court lacks jurisdiction to modify the sentence, even if the sentence may have been unauthorized. The court rejected the State’s request to create an exception for cases in which a District Court allegedly failed to follow appellate remand instructions, concluding that prior decisions distinguishing the rule did not establish such an exception. Appeal dismissed.

A25-1968 State v. Tillman (Blue Earth County)

Speedy Trial

Reason for Delay

Defendant appealed convictions for threats of violence and fourth-degree assault, arguing that extensive delays violated his constitutional right to a speedy trial, that his waiver of counsel was invalid, and that dismissal of two assault counts impaired a self-defense theory. The Court of Appeals held that, although the delay was presumptively prejudicial, the overwhelming majority of the delay was attributable to defendant’s own actions, including multiple competency proceedings, failure to appear, requests for continuances, failure to cooperate with a competency evaluation, and pretrial motions. The court further held that defendant’s repeated speedy-trial demands were undermined by conduct delaying resolution of the case and that he failed to demonstrate prejudice sufficient to establish a constitutional violation. The court also concluded that the District Court did not clearly err in determining that defendant knowingly, intelligently, and voluntarily waived counsel after multiple oral and written waivers and being offered an opportunity to consult with counsel. Finally, the court held that defendant forfeited his argument concerning self-defense by failing to support it with legal authority. Affirmed.

A25-0957 State v. Williams (Dakota County)

Sentencing

Criminal History Score

Defendant appealed his sentence for first-degree DWI, arguing that the District Court improperly included two prior Illinois convictions in his criminal-history score. The Court of Appeals held that the state failed to satisfy its burden of proving that the Illinois burglary and aggravated-fleeing convictions qualified for inclusion as felony-level offenses under the Minnesota Sentencing Guidelines. The record did not identify the Illinois statutes of conviction, the underlying conduct, or the sentences imposed, leaving insufficient evidence to determine whether the offenses would constitute Minnesota felonies and whether defendant received qualifying felony-level sentences. Reversed and remanded.

A25-1157 State v. Randle (Dakota County)

Criminal Order Opinions

Sentencing

Conditional Release

Petitioner appealed the denial of postconviction relief without an evidentiary hearing, arguing that the District Court unlawfully imposed a ten-year conditional-release term following his conviction for third-degree criminal sexual conduct and that a jury was required before such a term could be imposed. The Court of Appeals held that the petition failed as a matter of law. The court concluded that the version of Minn. Stat. § 609.3455 applicable to petitioner’s offense expressly required a ten-year conditional-release term for a conviction under Minn. Stat. § 609.344, making the sentence mandatory. Affirmed.

A25-1821 Gutierrez v. State (Ramsey County)

Trial

Stipulated Facts

Defendant appealed his conviction for possession of a firearm without a serial number following a stipulated-facts proceeding. On appeal, defendant argued that federal law did not require the firearm to bear a serial number. The Court of Appeals held that the argument was outside the permissible scope of appellate review in stipulated-facts proceedings. Because the parties had agreed to preserve only the District Court’s pretrial suppression ruling for review, the court’s review was limited to that dispositive pretrial issue. The court further held that defendant forfeited any challenge to the suppression ruling by failing to present legal argument or authority addressing the District Court’s denial of his motion to suppress. Affirmed.

A25-1263 State v. Chavis (Dakota County)