Minnesota Case Commentaries

Appellate Deference to DSM‑5‑TR–Based PTSD Diagnoses; Mootness Bars Consequential OSTD Claims; Frivolous Denials Penalized — Commentary on Peterson v. City of Minneapolis

Date: Jul 17, 2025

Appellate Deference to DSM‑5‑TR–Based PTSD Diagnoses; Mootness Bars Consequential OSTD Claims; Frivolous Denials Penalized Introduction In Lucas Peterson v. City of Minneapolis, Self-Insured, 23...

Limiting Dobbs: Minnesota Supreme Court Holds “New Interpretation” Exception Requires Case‑Specific Applicability; Untimely Postconviction Claims Not Revived by Abortion Jurisprudence

Date: Jul 17, 2025

Limiting Dobbs: Minnesota Supreme Court Holds “New Interpretation” Exception Requires Case‑Specific Applicability; Untimely Postconviction Claims Not Revived by Abortion Jurisprudence Introduction In...

“Uses Force” Under Minn. Stat. § 609.342, subd. 1(d): Bodily Harm Inflicted Before or During Nonconsensual Penetration Suffices

Date: Jul 10, 2025

“Uses Force” Under Minn. Stat. § 609.342, subd. 1(d): Bodily Harm Inflicted Before or During Nonconsensual Penetration Suffices Introduction In State of Minnesota v. Clifford Robert Letourneau, III,...

Presence Is Neither Necessary Nor Sufficient: Minnesota Clarifies the Hawkins Threshold for Alternative‑Perpetrator Evidence and Affirms Voluntariness of Hospital Interviews

Date: Jul 3, 2025

Presence Is Neither Necessary Nor Sufficient: Minnesota Clarifies the Hawkins Threshold for Alternative‑Perpetrator Evidence and Affirms Voluntariness of Hospital Interviews Introduction In State of...

Harmless Error for Unannounced Criminal History Scores and Reaffirmation of the Multiple‑Victim Exception in Consecutive Sentencing — Sanders v. State (Minn. 2025)

Date: Jul 3, 2025

Harmless Error for Unannounced Criminal History Scores and Reaffirmation of the Multiple‑Victim Exception in Consecutive Sentencing — Sanders v. State (Minn. 2025) Introduction In Milton K. Sanders...

State’s Right to Appeal Jail-Credit Awards After Probation Revocation Arises by Necessary Implication from Rule 27.04

Date: Jul 3, 2025

State’s Right to Appeal Jail-Credit Awards After Probation Revocation Arises by Necessary Implication from Rule 27.04 Case: State of Minnesota v. Jason Turner Johnson, 23 N.W.3d 70 (Minn. July 2,...

Unopposed Excess Fees Still Require Irwin Review; 2024 Workers’ Comp Fee Cap Applies Prospectively Only

Date: Jun 26, 2025

Unopposed Excess Fees Still Require Irwin Review; 2024 Workers’ Comp Fee Cap Applies Prospectively Only Introduction In James Jurgensen, Relator v. Dave Perkins Contracting, Inc., and TBG Claims...

Coleman and Noor Apply Retroactively; Knaffla Does Not Bar First Petitions Raising New Interpretations of Law

Date: Jun 19, 2025

Coleman and Noor Apply Retroactively; Knaffla Does Not Bar First Petitions Raising New Interpretations of Law Introduction In Carlos Heard v. State of Minnesota, 22 N.W.3d 154 (Minn. 2025), the...

Venue Under Minn. Stat. § 627.01 Is Not an Element: Guilty Plea Accuracy Need Not Include Venue Facts — State v. Paulson (Minn. 2025)

Date: Jun 12, 2025

Venue Under Minn. Stat. § 627.01 Is Not an Element: Guilty Plea Accuracy Need Not Include Venue Facts — State v. Paulson (Minn. 2025) Introduction In State of Minnesota v. Matthew Douglas Paulson, 22...

Torrez: No Probable-Cause Element for Warrant-Based Blood or Urine Test Refusal under Minn. Stat. § 169A.20, subd. 2(2)

Date: Jun 5, 2025

Torrez: No Probable-Cause Element for Warrant-Based Blood or Urine Test Refusal under Minn. Stat. § 169A.20, subd. 2(2) Introduction In State of Minnesota v. Samuel Alejondro Torrez, 21 N.W.3d 467...

Minnesota Supreme Court: WCCA May Vacate Awards Based on Invalid Workers’ Compensation Settlements and Decide Employee Incapacity Without District Court Referral

Date: May 22, 2025

Minnesota Supreme Court: WCCA May Vacate Awards Based on Invalid Workers’ Compensation Settlements and Decide Employee Incapacity Without District Court Referral Case: Bobby Lykins, by Conservator,...

Reading Multiple Liability-Shifting Clauses Together Under Strict Construction: Minnesota High Court Upholds Indemnity for a Party’s Own Negligence When the Contract Clearly Says So

Date: May 22, 2025

Reading Multiple Liability-Shifting Clauses Together Under Strict Construction: Minnesota High Court Upholds Indemnity for a Party’s Own Negligence When the Contract Clearly Says So Introduction In...

Primacy of the Watershed Law: Watershed Districts May Improve County Ditches Without Formal Transfer, and Need Only “Conform” to Chapter 103E

Date: May 15, 2025

Primacy of the Watershed Law: Watershed Districts May Improve County Ditches Without Formal Transfer, and Need Only “Conform” to Chapter 103E Introduction In a significant clarification of...

Market Rent Controls Potential Gross Income Absent Atypical Concessions; Occupancy Adjustments Must Align With Fee‑Simple Valuation

Date: May 15, 2025

Market Rent Controls Potential Gross Income Absent Atypical Concessions; Occupancy Adjustments Must Align With Fee‑Simple Valuation Case: Burnsville Medical Building, LLC v. County of Dakota, 20...

Estate Recovery in Managed Care: Minnesota Supreme Court Authorizes Recovery of Actuarially Determined Capitation Amounts for Long-Term Care After Age 55

Date: May 8, 2025

Estate Recovery in Managed Care: Minnesota Supreme Court Authorizes Recovery of Actuarially Determined Capitation Amounts for Long-Term Care After Age 55 Introduction In In re the Estate of: Joanne...

Trial Courts May Permit Alternative Perpetrators to Invoke the Fifth Before the Jury Once Hawkins Is Satisfied: Discretion, Not a Categorical Bar (State v. Foster)

Date: May 1, 2025

Trial Courts May Permit Alternative Perpetrators to Invoke the Fifth Before the Jury Once Hawkins Is Satisfied: Discretion, Not a Categorical Bar Case: State of Minnesota v. Larry Joe Foster...

"Lewdly" Means Conduct of a Sexual Nature: Minnesota Supreme Court Narrows Indecent-Exposure Liability in State v. Plancarte

Date: May 1, 2025

"Lewdly" Means Conduct of a Sexual Nature: Minnesota Supreme Court Narrows Indecent-Exposure Liability in State v. Plancarte Introduction In State of Minnesota v. Eloisa Rubi Plancarte (Supreme Court...

Clarifying “Ascertainable” Medical Benefits for Roraff Fees: WCCA Must Apply a Reasonable-Mind/Record-as-a-Whole Review

Date: May 1, 2025

Clarifying “Ascertainable” Medical Benefits for Roraff Fees: WCCA Must Apply a Reasonable-Mind/Record-as-a-Whole Review Court: Minnesota Supreme Court Case: Rodney Dean Bjornson, Relator v. McNeilus...

Impeachment-Only Evidence Cannot Revive Untimely Postconviction Petitions; “Interests of Justice” Requires an Injustice that Caused the Late Filing

Date: May 1, 2025

Impeachment-Only Evidence Cannot Revive Untimely Postconviction Petitions; “Interests of Justice” Requires an Injustice that Caused the Late Filing Case: Leroy Roderick Paul v. State of Minnesota, 20...

No Contemporaneity Requirement: “Operating” Need Not Occur at the Moment of Collision for Criminal Vehicular Homicide (Leaving the Scene) in Minnesota

Date: Apr 17, 2025

No Contemporaneity Requirement: “Operating” Need Not Occur at the Moment of Collision for Criminal Vehicular Homicide (Leaving the Scene) in Minnesota Introduction In State of Minnesota v. Henry Lee...