Court of Appeals Digest: June 22, 2026

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Civil Precedential

Parties

Intervention

Purchasers of real property and their lender sought to intervene in a breach-of-contract action after learning that a judgment entered against the seller had become a lien on the property. They argued that intervention was automatically accomplished under Minn. R. Civ. P. 24.03 because no party objected to their notice of intervention within 30 days and, alternatively, that they were entitled to intervention as of right or permissive intervention. The Court of Appeals held that, under Minn. R. Civ. P. 24, a District Court may reject intervention in an action even though no party timely objected to a notice of intervention. The court further concluded that appellants were not entitled to intervention as of right because they lacked a direct, legally protected interest in the subject matter of the underlying breach-of-contract action; their interest arose only indirectly through a judgment lien affecting property they later acquired. The court also held that the District Court acted within its discretion in denying permissive intervention, noting the absence of a protectable interest and the substantial prejudice that would result from reopening a settled case to litigate issues resolved by the original parties. Affirmed.

A25-1808 Texa Tonka Shopping Ctr., LLC v. JK 4 AL LLC LLC (Hennepin County)

Civil Nonprecedential

Breach of Contract

Damages

Plaintiff appealed a judgment entered after a jury found that defendant breached a repayment agreement but that the breach did not cause plaintiff any damages. The Court of Appeals held that, under the unique facts of the case, the jury’s findings were irreconcilable. The repayment agreement expressly acknowledged that defendant owed plaintiff a principal amount of $2,810,459, plus additional amounts under the agreement’s repayment formula, and the record showed that only a partial payment had been made. Although the District Court identified potential flaws and inconsistencies in plaintiff’s damages model, the court concluded that uncertainty regarding the precise amount of damages could not support a finding of no damages at all where the contract required payment of a definite monetary obligation that remained largely unpaid. The court also rejected defendant’s argument that plaintiff had effectively obtained the benefit of its bargain through control of the underlying business venture because the repayment agreement contemplated repayment in money and there was no evidence that the parties modified the agreement or reached an accord and satisfaction. Reversed and remanded.

A25-2055 BGD, LLC v. Burns (Carver County)

Default Judgment

Sanction

Defendants appealed the entry of default judgment and the denial of their motion to vacate the judgment under Minn. R. Civ. P. 60.02(a). The Court of Appeals held that the District Court acted within its discretion in entering default judgment as a sanction for repeated noncompliance with pretrial obligations. The court concluded that defendants failed to submit required pretrial materials, failed to attend a scheduled pretrial conference despite receiving notice, had previously failed to comply with discovery obligations, and had been expressly warned that noncompliance could result in default judgment. The court further determined that defendants’ conduct prejudiced plaintiffs, who had fully prepared for trial and incurred substantial expense. The court also upheld the denial of rule 60.02 relief, concluding that defendants failed to establish a reasonable excuse for their failure to comply with deadlines and appear at the pretrial hearing. Defendants’ assumptions regarding scheduling changes, difficulties retaining counsel, and pro se status did not excuse their noncompliance. Affirmed.

A25-1569 Fitchett v. Dolezal Creative Design Build Inc. (Hennepin County)

Domestic Relations

Child Custody; Modification

Father appealed an order denying his motion to modify custody and granting mother permission to relocate the parties’ child to Slovakia. The Court of Appeals held that the District Court properly denied father’s custody-modification motion without an evidentiary hearing because father failed to establish a prima facie case for modification. The court concluded that father’s allegations largely repeated issues raised in prior proceedings, lacked specific evidence of changed circumstances or endangerment, and did not demonstrate that a custody change would serve the child’s best interests. The court also held that the District Court acted within its discretion in granting mother’s relocation request without an evidentiary hearing because Minnesota’s relocation statute does not require one and the matter could be decided on the parties’ written submissions. Finally, the court determined that the District Court correctly applied Minn. Stat. § 518.175, subd. 3, thoroughly analyzed the statutory best-interests factors governing relocation, and reasonably concluded that relocation was in the child’s best interests. Affirmed.

A25-1919 Bachmayer v. Bachmayer (Hennepin County)

Domestic Relations

Child Custody; Third Party

Mother appealed an order granting third-party custody of her child to the child’s aunt and uncle, arguing that they did not qualify as interested third parties, that the District Court improperly weighed the child’s best interests, and that the court mishandled contempt proceedings against the child’s former custodians. The Court of Appeals held that the District Court acted within its discretion in awarding third-party custody. The court concluded that the record supported findings that the parents had abandoned the child and that placement with the third parties was necessary to protect the child from emotional harm. The court further determined that the District Court properly considered the statutory best-interests factors, including evidence regarding the child’s longstanding placement, the parents’ circumstances, and the child’s need for stability. The court also upheld the District Court’s handling of the contempt proceedings. Affirmed.

A25-1474 Whited v. Quinn (In re Custody of L.B.O.) (Dakota County)

Domestic Relations

Dissolution; Marital Property

Husband appealed a dissolution judgment, arguing that the District Court erred in valuing marital assets, finding dissipation of marital property, drawing adverse inferences from his failure to provide financial records, and calculating income for child-support purposes. The Court of Appeals held that the District Court properly concluded that husband dissipated marital assets based on evidence of substantial unaccounted-for transfers and his repeated failure to comply with discovery orders. The court also upheld the District Court’s use of adverse inferences and its determination that husband was voluntarily unemployed while attending law school, affirming the calculation of his potential income for child-support purposes. However, the court determined that the District Court double-counted a portion of the dissipated assets by including the same transfers in both pre- and post-valuation-date dissipation calculations. Affirmed in part, reversed in part, and remanded.

A25-1173 Ali v. Ibrahim (Lyon County)

Domestic Relations

Dissolution; Marital Property

Wife appealed the classification and division of property following dissolution of the parties’ second marriage, arguing that funds she received from a personal-injury settlement arising from a pre-marriage accident, and assets purchased or improved with those funds, should have been treated as nonmarital property. The Court of Appeals affirmed the District Court’s determination that the settlement proceeds were marital property. Although the injury occurred before the second marriage, wife failed to establish the purpose of the settlement recovery because she did not produce the settlement agreement or other evidence showing what portion of the payment compensated nonmarital losses such as pain and suffering rather than marital claims such as lost wages. The court further held that the District Court’s imposition of a $100,000 lien on the marital home, in addition to a $75,000 equalization payment, lacked sufficient findings to permit meaningful appellate review. Affirmed in part and remanded.

A25-0756 Honeman v. Honeman (Brown County)

Domestic Relations

Dissolution; Marital Property

In a marital-dissolution appeal following a 30-year marriage, both parties challenged the District Court’s property division, spousal-maintenance award, attorney-fee rulings, and valuation of marital assets. The Court of Appeals affirmed the District Court’s valuation of the husband’s interests in two closely held businesses, its valuation and ordered sale of Florida real estate, its attribution of liability for a mortgage obtained without the husband’s consent, and its attorney-fee rulings. However, the court held that the District Court committed several errors in calculating the marital estate, including double-counting funds held in a bank account opened after the valuation date, assigning tax liabilities while simultaneously ordering amended tax filings that would eliminate those liabilities, failing to adequately account for certain bonus and property-tax amounts, and improperly characterizing certain transferred funds and a vehicle purchase as dissipation of marital assets. The court also concluded that the spousal-maintenance award could not be meaningfully reviewed because the District Court failed to adequately explain the obligor’s expenses and improperly considered adult children’s college expenses when evaluating maintenance. Affirmed in part, reversed in part, and remanded.

A25-0142, A25-0425 Knutsen v. Knutsen (Hennepin County)

Eminent Domain

Fees

In an eminent-domain proceeding, a landowner sought attorney fees, costs, and expenses after commissioners awarded damages of $1.1 million—more than 40% greater than the condemning authority’s last written offer of approximately $489,000. The condemning authority argued that, as a public service corporation, it was exempt from Minnesota’s attorney-fee statute. The Court of Appeals held that an exception to the exemption applied because the taking was for construction of an “ancillary substation” under Minn. Stat. § 117.189(a)(1). Interpreting the statute, the court concluded that the phrase “ancillary substations” includes substations subordinate to high-voltage transmission lines of 100 kilovolts or more, regardless of the voltage directly received by the substation itself. Relying on the statutory text, legislative history, and the legislature’s intent to protect landowners from undervaluation in large utility projects, the court determined that the distribution substation at issue qualified as an ancillary substation. Because the commissioners’ award exceeded the statutory threshold and the exception applied, the District Court properly awarded attorney fees, costs, and expenses. Affirmed.

A25-1765 Wright-Hennepin Coop. Elec. Assoc. v. Sween (Hennepin County)

Fraudulent Transfers

Jurisdiction

Judgment creditors brought claims under the Minnesota Uniform Voidable Transactions Act (MUVTA), alleging that a judgment debtor transferred assets through family members and a related company to purchase Minnesota real estate in order to hinder, delay, or defraud collection efforts. After a jury returned a verdict for the creditor, the defendants appealed the denial of their motions for judgment as a matter of law and for a new trial. The Court of Appeals affirmed. The court held that Minnesota courts had personal jurisdiction over an out-of-state defendant who registered a business in Minnesota, conducted business in the state, and purchased the subject Minnesota property through that entity. The court further concluded that the MUVTA claim was timely because it was brought within six years of the underlying judgment and that MUVTA claims are statutory fraudulent-transfer claims, not common-law fraud claims subject to heightened pleading requirements. The court also rejected claims that the plaintiff changed theories during trial, that the District Court improperly prevented the jury from reviewing the complaint during deliberations, and that damages evidence had not been disclosed in discovery. Affirmed.

A25-2146 Wall v. Jeffs (Cook County)

Harassment Restraining Orders

Notice

Appellant challenged a harassment restraining order (HRO), arguing that he lacked adequate notice that the scheduled hearing would be evidentiary in nature, that the evidence was insufficient to support the HRO, and that the District Court improperly excluded his documentary evidence. The Court of Appeals affirmed. The court held that appellant received adequate notice of the hearing through the ex parte HRO and subsequent hearing notice, both of which informed him of his opportunity to contest the allegations. The court further concluded that the record supported the District Court’s findings that appellant engaged in repeated unwanted acts, communications, and social-media activity that adversely affected the petitioner’s safety, security, or privacy, satisfying the statutory definition of harassment. Finally, the court determined that appellant was not prejudiced by the exclusion of post-hearing documentary submissions because the District Court later reviewed those materials in connection with appellant’s motion to vacate and found that they did not rebut the harassment findings. Affirmed.

A25-1729 Dosso v. Dosso (Clay County)

Insurance

Homeowner Insurance

Homeowner appealed summary judgment dismissing claims that his insurer underpaid benefits for hail damage to his property. He argued that a homeowner’s policy provision requiring repairs to be completed within two years of the loss to recover replacement-cost value conflicted with Minnesota’s standard fire-insurance statute and that the insurer was required to show prejudice before denying replacement-cost benefits. The Court of Appeals rejected both arguments. The court held that Minn. Stat. § 65A.01 does not guarantee payment of every amount identified in an appraisal award and does not prohibit an insurer from conditioning replacement-cost coverage on timely completion of repairs. The court further concluded that an appraisal determines the amount of loss but does not resolve coverage obligations under the policy. The court also held that the policy’s requirement that repairs be completed within two years of the date of loss was an unambiguous condition precedent to recovery of replacement-cost value. Because the insured did not satisfy that condition, the insurer was not required to demonstrate prejudice to deny replacement-cost benefits. Affirmed.

A25-1837 LaVigne v. State Farm Fire & Cas. Co. (Wabasha County)

Medical Malpractice

Expert Affidavit

Plaintiff appealed the dismissal of a wrongful-death action arising from the death of a resident at an inpatient substance-abuse and mental-health treatment facility. Plaintiff argued that the claim sounded in ordinary negligence rather than medical malpractice and therefore was not subject to the expert-review affidavit requirements of Minn. Stat. § 145.682. The Court of Appeals held that the claim was one for medical malpractice because the alleged duty to secure potentially harmful substances from residents depended on professional judgment concerning the resident’s diagnosis, treatment, and level of supervision. The court further concluded that expert testimony was necessary to establish the applicable standard of care and any breach because those issues were beyond the common knowledge of lay jurors. Affirmed.

A25-0998 Carpenter v. Meridian Behav. Health LLC (Washington County)

Unemployment Benefits

Employment Misconduct

Relator appealed a determination that he was ineligible for unemployment benefits because he was discharged for employment misconduct following an off-duty altercation on a casino shuttle bus. The Court of Appeals held that substantial evidence supported the unemployment-law judge’s finding that relator violated employer policies requiring professional and respectful conduct toward guests and others while on casino property. The court concluded that the ULJ properly relied on video evidence and witness testimony showing that relator engaged in a verbal confrontation and later provided an account of the incident that was inconsistent with the video footage. The court also rejected relator’s challenges to the ULJ’s credibility determinations, finding that the ULJ adequately explained why the video evidence was the most reliable evidence when testimony conflicted. Affirmed.

A25-2042 Chaudhry v. Mystic Lake Casino (Dep’t of Emp’t & Econ. Dev.)

Unemployment Benefits

Employment Misconduct

Relator appealed a determination that she was ineligible for unemployment benefits because she was discharged for employment misconduct. She argued that the unemployment-law judge’s factual findings were unsupported by the record and that her discharge was retaliatory because she had reported concerns about resident care to a state agency. The Court of Appeals held that substantial evidence supported the finding of employment misconduct. The court concluded that relator intentionally violated standards of behavior her employer had a right to expect by making profane and disparaging comments about a supervisor in the presence of subordinates and by telling subordinate employees that the employer would be shut down by the state. Affirmed.

A25-1508 Johnson v. Mentor Management Inc. (Dep’t of Emp’t & Econ. Dev.)

Civil Order Opinions

Judgments

Review

Appellant challenged a District Court order clarifying how proceeds from a judgment obtained against a former client should be distributed between appellant and his former law firm. After the former client paid the judgment to the law firm, the District Court directed the firm to disburse a specified amount to appellant and use the remaining funds to satisfy applicable tax-withholding obligations. The Court of Appeals affirmed. The court held that appellant’s argument that the District Court improperly clarified the judgment was forfeited because he failed to support the claim with legal analysis or citation to authority. The court also declined to consider appellant’s res judicata argument because it had not been raised before the District Court. Affirmed.

A26-0175 Knutson v. Moore (St. Louis County)

Domestic Relations

Child Custody; Evidence

Father appealed an order awarding mother sole legal and sole physical custody of the parties’ children and limiting father to supervised parenting time. Acting pro se, father argued that the District Court violated various constitutional rights, made erroneous factual findings, committed evidentiary errors, and demonstrated judicial bias. The Court of Appeals affirmed. The court held that father failed to preserve evidentiary challenges for appellate review and did not adequately brief or support his constitutional claims with legal argument. The court further concluded that father failed to demonstrate any prejudicial error in the District Court’s factual findings. Affirmed.

A25-2005 In re Custody of Children of Watkins (Sibley County)

Criminal Nonprecedential

Assault

Great Bodily Harm

Defendant appealed convictions for first-degree assault, third-degree assault, and violating a domestic-abuse no-contact order. He argued that the evidence was insufficient to establish the great-bodily-harm element of first-degree assault, challenged several evidentiary rulings, alleged prosecutorial misconduct, and sought a new trial based on cumulative error. The Court of Appeals held that the evidence was sufficient to prove great bodily harm because the victim sustained a permanent orbital fracture that caused lasting and visible asymmetry of the eye, constituting serious permanent disfigurement. The court further concluded that the District Court did not abuse its discretion in its challenged evidentiary rulings, including rulings concerning rebuttal testimony, relationship evidence, and recorded recollections. Although the court determined that testimony identifying defendant as the assailant was erroneously admitted under the medical-diagnosis hearsay exception, the error did not affect defendant’s substantial rights in light of the strong evidence of guilt. The court also rejected claims of prosecutorial misconduct, concluding that none of the challenged conduct warranted relief. Affirmed.

A25-1032 State v. Sheldon (Ramsey County)

Assault

Intent

Defendant appealed convictions for second-degree assault with a dangerous weapon and threats of violence, arguing that the State failed to prove the required intent. The Court of Appeals held that the evidence was sufficient to support both convictions. Applying the circumstantial-evidence standard, the court concluded that the circumstances proved were consistent only with the inference that defendant intended to cause fear of immediate bodily harm or death and acted with at least reckless disregard of the risk of causing terror. The court emphasized evidence that defendant intentionally pursued and confronted an unarmed 13-year-old, blocked his path, held a firearm within inches of the child’s head while angrily accusing him of attempting to steal dogs, and continued the confrontation at the child’s home. The court rejected defendant’s claim that he possessed the firearm solely for self-defense, noting that he knew the dogs were already safe, never observed a weapon, and voluntarily initiated the confrontation. Affirmed.

A24-1836 State v. Waagen (Morrison County)

Incarceration

Challenge Incarceration Program

An inmate appealed the dismissal of his action seeking admission to Minnesota’s Challenge Incarceration Program (CIP). He argued that Minn. Stat. § 244.17, subd. 3(2), disqualified only offenders whose current commitment to the commissioner resulted from a qualifying conviction within the preceding ten years and that his prior out-of-state assault and robbery convictions therefore did not render him ineligible. The Court of Appeals rejected that interpretation and held that the statute unambiguously establishes two separate eligibility requirements: (1) a conviction within the preceding ten years for one of the enumerated offenses and (2) commitment to the commissioner’s custody. The court concluded that the statute does not require a causal connection between the qualifying conviction and the offender’s current incarceration. Because appellant had qualifying convictions within the preceding ten years and was committed to the commissioner’s custody, he was statutorily ineligible for CIP participation. Affirmed.

A25-2034 Walker v. Schnell (Ramsey County)

Indecent Exposure

Jury Instructions

Defendant appealed his conviction for gross-misdemeanor indecent exposure, arguing that the jury received an incorrect instruction defining the statutory term “lewdly.” After trial, the Minnesota Supreme Court interpreted “lewdly” in the indecent-exposure statute to mean conduct of a sexual nature, rather than conduct that is merely lustful or indecent. Assuming without deciding that the jury instruction constituted plain error, the Court of Appeals held that defendant failed to establish that the error affected his substantial rights. The court emphasized the overwhelming evidence that defendant’s conduct was sexual in nature, including testimony that he exposed and held his penis while making a sexual remark to the victim, as well as statements made during a police interview. Affirmed.

A25-1139 State v. Johnson (Ramsey County)

Ineffective Assistance of Counsel

Deficient Performance

Petitioner appealed the denial of postconviction relief, seeking to withdraw his guilty plea to first-degree aggravated robbery on the ground that plea counsel rendered ineffective assistance by failing to advise him that the conviction would make deportation presumptively mandatory. The Court of Appeals held that the District Court’s factual finding—that counsel informed petitioner of the immigration consequences of the plea—was supported by the record. The court relied on counsel’s affidavit establishing that he had consulted with an immigration specialist, understood that the offense would subject petitioner to presumptively mandatory deportation, and customarily explained those consequences to clients. Affirmed.

A25-1876 Aguilar-Pineda v. State (Ramsey County)

Ineffective Assistance of Counsel

Deficient Performance

Defendant appealed the denial of postconviction relief from his conviction for second-degree intentional murder, arguing that trial counsel rendered ineffective assistance by failing to pursue an alternative-perpetrator defense and by not introducing evidence that other white SUVs were present near the crime scene. The Court of Appeals held that defendant failed to satisfy the performance prong. The court concluded that decisions whether to pursue an alternative-perpetrator theory and what evidence to present are matters of trial strategy that generally are not subject to appellate review. The record showed that counsel investigated the proposed alternative suspect, considered the available evidence, and made a strategic decision not to pursue the defense because the evidence was weak and risked reinforcing the State’s motive theory while undermining the defense strategy of attacking the reliability and sufficiency of the State’s evidence. The court further determined that counsel’s decision not to introduce evidence of other white SUVs in the area likewise reflected a reasoned strategic choice. Affirmed.

A24-0237 State v. Johnson (Ramsey County)

Ineffective Assistance of Counsel

Prejudice

Defendant appealed the denial of postconviction relief from his convictions for second-degree assault and firearm possession, arguing that trial counsel rendered ineffective assistance by failing to timely stipulate to a prior conviction, failing to timely object to evidence of alleged prior bad acts, failing to object to hearsay, eliciting hearsay testimony, and introducing evidence linking him to incriminating text messages. The Court of Appeals held that several of counsel’s actions were objectively unreasonable, including the failure to timely stipulate to a prior conviction, the failure to timely object to inadmissible other-acts evidence, and the introduction of evidence connecting defendant to incriminating messages. However, the court concluded that defendant failed to establish prejudice under Strickland. The court reasoned that the challenged evidence was either mitigated by jury instructions, cumulative of other properly admitted evidence, or unlikely to have affected the verdict. The court further held that counsel’s decisions regarding hearsay objections and cross-examination reflected reasonable trial strategy and were not subject to second-guessing on appeal. Affirmed.

A23-1892 State v. Powell (Ramsey County)

Murder

Sufficiency of the Evidence

Defendant appealed his conviction of second-degree intentional murder, arguing that the circumstantial evidence was insufficient to prove that he caused the victim’s death or acted with intent to kill. He also challenged the District Court’s imposition of a top-of-the-box guidelines sentence, the calculation of jail credit, and the imposition of a monetary fine. The Court of Appeals held that the evidence was sufficient to support the conviction because the circumstances proved were consistent with guilt and inconsistent with any rational hypothesis other than guilt, including theories that another person committed the offense or that defendant lacked intent to kill. The court further held that the District Court acted within its discretion by imposing the longest sentence within the presumptive guidelines range. However, the court determined that the District Court used an incorrect arrest date when calculating custody credit and that defendant was entitled to seven additional days of jail credit. The court also held that the District Court lacked statutory authority to impose a fine because the second-degree murder statute authorizes imprisonment but not a monetary penalty. Affirmed in part, reversed in part, and remanded.

A25-0859 State v. Icanberry (Clay County)

Plea Withdrawal

Fair & Just

Defendant appealed his conviction for unlawful possession of a firearm, arguing that he should be allowed to withdraw his guilty plea, that the District Court improperly ordered restitution, and that the court should have granted a downward dispositional departure. The Court of Appeals held that the District Court properly denied plea withdrawal under both the fair-and-just and manifest-injustice standards. The court concluded that defendant failed to provide a substantiated basis for withdrawal and that the plea was intelligent despite the lack of discussion regarding restitution because the record showed defendant had notice that restitution could be sought. The court also upheld the denial of a dispositional departure. However, the court held that the restitution order must be reversed because, although the record contained information regarding defendant’s financial circumstances, the District Court failed to expressly state that it considered defendant’s income, resources, and obligations before imposing restitution as required by Minnesota law. Affirmed in part, reversed in part, and remanded.

A25-1342 State v. Merrill (Otter Tail County)

Postconviction Relief

Evidentiary Hearing

Petitioner appealed the denial of postconviction relief from his convictions for second-degree criminal sexual conduct, arguing that the postconviction court erred by denying his ineffective-assistance-of-counsel claims without an evidentiary hearing. The Court of Appeals held that an evidentiary hearing was not required because the petition did not identify material facts outside the existing record that, if proven, would entitle petitioner to relief. The court further concluded that petitioner failed to establish ineffective assistance under the Strickland standard. The court determined that trial counsel’s assessment that petitioner had a reasonable chance of success at trial reflected a plausible trial strategy rather than objectively unreasonable advice. The court also held that petitioner failed to demonstrate prejudice from counsel’s alleged failure to further investigate witnesses’ motives to fabricate allegations because evidence regarding those motives was presented at trial and petitioner did not show a reasonable probability of a different outcome. Affirmed.

A25-1732 Schaefer-Bonovsky v. State (Stearns County)

Prosecutorial Misconduct

Closing Argument

Defendant appealed a first-degree arson conviction, arguing that she was denied a fair trial by multiple instances of prosecutorial misconduct, including comments regarding the police investigation, motive, defense theories, profile evidence, and the State’s burden of proof. The Court of Appeals held that none of the challenged conduct warranted reversal. The court concluded that the prosecutor’s comments regarding the investigation properly reminded jurors to decide the case based on the evidence rather than speculation. The court further held that the prosecutor accurately stated that motive was not an element of first-degree arson and permissibly argued that the defense theories lacked merit. The court also rejected claims that the prosecutor improperly elicited profile evidence or diluted the State’s burden of proof, determining that any alleged error was not plain under existing law. Affirmed.

A25-1348 State v. Boos (Hennepin County)

Spreigl Evidence

Common Scheme or Plan

Defendant appealed his conviction for first-degree criminal sexual conduct, arguing that the District Court abused its discretion by admitting evidence of prior sexual misconduct involving another victim. The Court of Appeals held that the evidence was properly admitted to establish a common scheme or plan. The court concluded that the prior acts and charged conduct shared marked similarities, including the parties’ familial relationships, defendant’s position of trust and supervision, the circumstances under which the conduct occurred, and efforts to prevent disclosure. The court further determined that the incidents were sufficiently close in time and place and that the evidence was highly probative because the case depended largely on witness credibility and lacked substantial corroborating evidence. Affirmed.

A25-0781 State v. Gomez (Clay County)

Spreigl Evidence

Instructions

Defendant appealed convictions for first-degree robbery, unlawful possession of a firearm, and second-degree assault, arguing that the District Court erred by failing to give a contemporaneous cautionary instruction when Spreigl evidence was admitted and by admitting video and photographic Spreigl evidence without proper authentication. The Court of Appeals held that neither claim warranted relief under plain-error review. The court concluded that, although District Courts are encouraged to provide limiting instructions both when Spreigl evidence is admitted and again during final instructions, existing precedent does not require a District Court to give such an instruction sua sponte absent a request. The court also held that the challenged videos and photographs were properly authenticated through testimony establishing the chain of custody of defendant’s phone and the reliability of the process used to locate and record the images. Affirmed.

A25-1477 State v. Yusuf (Stearns County)

Criminal Order Opinions

Postconviction Relief

Knaffla Bar

Petitioner appealed the denial of his motion for leave to file another postconviction petition challenging convictions for soliciting a minor to engage in prostitution, engaging in prostitution with a minor, and kidnapping. The Court of Appeals affirmed. The court held that petitioner’s claims—including challenges based on the single-behavioral-incident rule, sentencing, jury instructions, and ineffective assistance of counsel—were procedurally barred under the Knaffla doctrine because they either had been raised previously or could have been raised in earlier postconviction proceedings. The court noted that petitioner had filed numerous prior petitions and motions over more than two decades and failed to demonstrate that his current claims relied on newly discovered information or that any exception to the Knaffla bar applied. Affirmed.

A26-0167 Dillard v. State (Ramsey County)