Supreme Court Digest: June 3, 2026

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Civil

Public Employment

Line-of-Duty Death Benefits

Widow of a police officer who died from a vascular rupture sought line-of-duty death benefits under Minn. Stat. §§ 299A.41–.47. The Commissioner of Public Safety denied the application, concluding that Groebner had not died “in the line of duty” as defined by the statute, and an ALJ granted summary disposition for the Commissioner. The Court of Appeals reversed and remanded. It held that the ALJ had applied an incorrect legal framework by relying on the Minnesota Supreme Court‘s decisions in Kramer and Johnson to determine whether the statutory presumption applied.

The Supreme Court held that (1) a public safety officer who dies from a heart attack, stroke, or vascular rupture is presumed to have been “killed in the line of duty” if the death meets the presumption criteria under Minn. Stat. § 299A.41, subd. 3(a). For purposes of the presumption criteria under subdivision 3(a)(1)(i), an emergency response is presumptively “nonroutine” regardless of how the public safety agency characterizes the emergency response or whether the emergency response is frequently performed, and the phrase “nonroutine stressful or strenuous physical” modifies the entire series of items following it: “law enforcement, fire suppression, rescue, hazardous material response, emergency medical services, prison security, disaster relief, or other emergency response activity.” (2) If the death does not satisfy the presumption criteria or if the Commissioner of Public Safety rebuts the presumption with competent medical evidence, the officer’s estate can present its own medical evidence to show that the officer was “killed in the line of duty” under Kramer v. State, Peace Officers Ben. Fund, 380 N.W.2d 497 (Minn. 1986), and Johnson v. City of Plainview, 431 N.W.2d 109 (Minn. 1988). Affirmed in part, reversed in part.

A24-1410 In re Pub. Safety Officer Death Benefit for Groebner (Court of Appeals)

Taxes

Underreporting

The tax dispute here concerns the Commissioner of Revenue’s application of the 6½-year statute of limitations under Minn. Stat. § 289A.38, subd. 6, which extends the time for the Commissioner to assess taxes in cases of substantial underreporting, and the Commissioner’s imposition of a penalty under Minn. Stat. § 289A.60, subd. 5, which penalizes a taxpayer’s negligence or intentional disregard of applicable tax laws and rules. Relator taxpayer operates a retail business selling liquor and other products that are subject to sales tax. Following an audit, the Commissioner issued a Tax Order, determining that relator owed additional sales tax for the period of January 2015 through June 2020, along with penalties and interest totaling $639,461.56. Relator appealed the Commissioner’s decision, and the Tax Court granted summary judgment for the Commissioner.

The Supreme Court held that (1) the Tax Court did not err when it concluded that the Commissioner properly extended the statute of limitations period to 6½ years under Minn. Stat. § 289A.38, subd. ; and (2) the Tax Court did not err when it concluded that the Commissioner’s imposition of the negligence penalty under Minn. Stat. § 289A.60, subd. 5 was proper. Affirmed.

A25-1191 PASCP Inc. v. Comm’r of Rev. (Tax Court)