Emergency Responses Are Presumptively “Nonroutine” Under Minn. Stat. § 299A.41 and Kramer/Johnson Remain an Alternative Path to Line-of-Duty Benefits

Case: In the Matter of a Public Safety Officer Death Benefit for Eric William Groebner (Deceased)
Court: Supreme Court of Minnesota
Date: June 3, 2026

1. Introduction

This decision addresses Minnesota’s line-of-duty death benefits scheme for public safety officers who die from heart-related events. The statute, Minn. Stat. §§ 299A.41–.47, provides a one-time death benefit when an officer is “killed in the line of duty.” Historically, “deaths from natural causes” were excluded, leaving courts to decide when heart-related deaths nonetheless qualified. In 2016, the Legislature added a rebuttable presumption for deaths caused by a “heart attack, stroke, or vascular rupture” if specified on-duty “nonroutine stressful or strenuous physical” criteria are met.

Officer Eric William Groebner, an Anoka patrol officer, worked a 12-hour shift responding to 11 calls. He died the next day from a vascular rupture. His widow, Holly Groebner, received federal PSOB benefits but was denied Minnesota benefits by the Commissioner of Public Safety. The case raised two core issues:

• Interpretation: What does “nonroutine” mean in Minn. Stat. § 299A.41, subd. 3(a)(1)(i), and what does the phrase “nonroutine stressful or strenuous physical” modify?
• Continuing vitality of precedent: After the 2016 presumption, can a claimant still prove line-of-duty causation under Kramer and Johnson if the presumption does not apply or is rebutted?

2. Summary of the Opinion

The Minnesota Supreme Court affirmed the court of appeals insofar as it held that summary disposition was improper: viewing the record in the light most favorable to Ms. Groebner, genuine issues of material fact remained regarding whether the officer engaged in qualifying “nonroutine stressful or strenuous physical” activity in the 24-hour window.

But the Court reversed the court of appeals on an important doctrinal point: the 2016 statutory presumption did not eliminate the ability to prove “killed in the line of duty” under the pre-2016 Minnesota Supreme Court standards from Kramer v. State, Peace Officers Ben. Fund and Johnson v. City of Plainview. Instead, the presumption creates a burden-shifting shortcut; when it fails or is rebutted, claimants may proceed under Kramer/Johnson with medical evidence.

3. Analysis

3.1 Precedents Cited (and How They Shaped the Decision)

A. Minnesota “killed in the line of duty” heart-death doctrine

• Kramer v. State, Peace Officers Ben. Fund, 380 N.W.2d 497 (Minn. 1986)
  Role in this opinion: Kramer supplies the foundational common-law definition: “killed in the line of duty” means death resulting from performing duties “peculiar to a peace officer” that “expose the officer to the hazard of being killed.” The Court uses Kramer in two ways: (i) to clarify the pre-2016 baseline (heart deaths can qualify if tied to hazardous duty), and (ii) as a continuing “backstop” standard when the statutory presumption does not apply or is rebutted. The Court also emphasizes a limiting principle implicit in Kramer: benefits focus on specific instances of hazardous duty, not generalized long-term occupational stress.
• Johnson v. City of Plainview, 431 N.W.2d 109 (Minn. 1988)
  Role in this opinion: Johnson applied Kramer to firefighters who suffered fatal heart-related events while engaged in firefighting tasks, holding their deaths were not “natural causes” under the statute because the deaths resulted in part from hazardous public protection work. Here, the Court relies on Johnson to demonstrate (i) the historic breadth of line-of-duty coverage for heart-related deaths tied to hazardous duty, and (ii) that the 2016 amendments did not clearly abrogate this established common-law rule.

B. Minnesota rules of statutory interpretation

• Rodriguez v. State Farm Mut. Auto. Ins. Co., 931 N.W.2d 632 (Minn. 2019)
  Used for the primacy of plain meaning: clear statutory language controls.
• In re Welfare of J.B., 782 N.W.2d 535 (Minn. 2010)
  Supplies the ambiguity standard: a term is ambiguous when reasonably susceptible to more than one interpretation.
• Getz v. Peace, 934 N.W.2d 347 (Minn. 2019)
  Supports using dictionary definitions for common usage when the Legislature has not defined a term—central to the Court’s conclusion that “nonroutine” is ambiguous.
• Scheurer v. Shrewsbury, 24 N.W.3d 670 (Minn. 2025)
  Supports consulting legislative history and recognizing that a bill sponsor’s explanation may carry weight—critical to the Court’s reliance on 2016 testimony indicating the goal of conforming state and federal benefits determinations.
• State v. Stickney, 5 N.W.2d 351 (Minn. 1942) and Minn. Citizens Concerned for Life, Inc. v. Kelley, 698 N.W.2d 424 (Minn. 2005)
  Provide the “copied-from-federal-law” interpretive principle: when a Minnesota statute mirrors a federal one, prior federal construction is persuasive/controlling—forming the doctrinal bridge to federal PSOB sources to define “nonroutine.”
• Great N. Invs., Inc. v. Comm’r of Tax’n, 127 N.W.2d 444 (Minn. 1964)
  Reinforces the use of federal interpretations when Minnesota adopts similar language.
• ILHC of Eagan, LLC v. County of Dakota, 693 N.W.2d 412 (Minn. 2005)
  Supports using grammar rules and natural usage, setting up the Court’s application of the series-qualifier rule.
• State v. Khalil, 956 N.W.2d 627 (Minn. 2021) and State v. Stay, 935 N.W.2d 428 (Minn. 2019)
  Provide the series-qualifier framework. The Court uses these cases to hold that “nonroutine stressful or strenuous physical” modifies every item in the ensuing list.
• State v. Riggs, 865 N.W.2d 679 (Minn. 2015)
  Supplies the “statute as a whole” harmonization principle, used to reject the Commissioner’s reading that the presumption necessarily supplants Kramer/Johnson.
• Zephier v. Agate, 957 N.W.2d 866 (Minn. 2021)
  Underwrites the anti-abrogation canon: the Legislature is not presumed to abrogate common law absent clear intent. This is pivotal to preserving Kramer/Johnson as an alternative route to benefits.
• Cox v. Mid-Minn. Mut. Ins. Co., 909 N.W.2d 540 (Minn. 2018)
  Used to justify treating “presumption” as a technical legal term with an established burden-shifting meaning.

C. Summary disposition/summary judgment standards

• Pietsch v. Minn. Bd. of Chiropractic Exam’rs, 683 N.W.2d 303 (Minn. 2004)
  Establishes that summary disposition is the administrative analogue to summary judgment and is reviewed for genuine disputes of material fact and errors of law.
• Henson v. Uptown Drink, LLC, 922 N.W.2d 185 (Minn. 2019)
  Provides the rule to view evidence in the light most favorable to the nonmoving party—central to the Court’s conclusion that factual disputes remain about whether the shift involved qualifying activity.

D. Presumptions as burden-shifting (analogies)

• Juntunen v. Carlton County, 982 N.W.2d 729 (Minn. 2022)
  Demonstrates that when a statutory presumption is rebutted, the presumption disappears but the claimant may still prove entitlement under ordinary standards.
• Hanson v. Dep’t of Nat. Res., 972 N.W.2d 362 (Minn. 2022)
  Used by analogy (McDonnell Douglas) to show that rebuttal typically returns the burden to the claimant rather than ending the case.

E. Federal sources used to align Minnesota’s 2016 presumption

• Watkins v. Department of Justices, 809 Fed. Appx. 923 (Fed. Cir. 2020) and Afolayan v. Department of Justice, No. 2021-1452, 2022 WL 1124965 (Fed. Cir. Apr. 15, 2022)
  These are cited as illustrative federal applications of the “nonroutine” requirement under the federal PSOB scheme. The Minnesota Court treats them as informative context (not binding), reinforcing that federal practice distinguishes routine activity from qualifying “nonroutine stressful or strenuous physical” activity.
• In re Issuance of Air Emissions Permit No. 13700345-101 for PolyMet Mining, Inc., City of Hoyt Lakes, St. Louis Cnty., Minn., 955 N.W.2d 258 (Minn. 2021)
  Cited for the proposition that informal federal agency interpretations may be persuasive; this supports the Court’s reliance on the BJA’s October 2007 memorandum as part of the federal interpretive ecosystem.

3.2 Legal Reasoning

A. “Nonroutine” is ambiguous; federal conformity resolves the ambiguity

The Court begins with the text. “Nonroutine” is not statutorily defined; dictionary definitions of “routine” point in more than one plausible direction (“habitual/regular” versus “ordinary/no special quality”), making “nonroutine” ambiguous under In re Welfare of J.B..

The Court then pivots to the 2016 amendments’ purpose: legislative history shows the Legislature intended to bring Minnesota’s definition into “conformity” with the federal PSOB heart-death presumption and to facilitate a “one-stop shop” benefits determination. Because Minnesota’s presumption language is substantially similar to the federal statute, the Court applies the copied-statute canon (State v. Stickney; Minn. Citizens Concerned for Life, Inc. v. Kelley), looking to federal regulations and BJA policy.

That federal framework (including 28 C.F.R. § 32.13 and the October 2007 BJA memo) explicitly rejects treating an action as “routine” based on either agency characterization or frequency. From that, the Court adopts a Minnesota rule: emergency responses are presumptively “nonroutine.”

B. The “nonroutine stressful or strenuous physical” requirement applies to all listed activities

Applying the series-qualifier rule (State v. Khalil), the Court holds the modifier “nonroutine stressful or strenuous physical” applies to each item in the list—law enforcement through “other emergency response activity.” This prevents “emergency response activity” from becoming an unqualified catchall that would trigger the presumption without the statute’s core requirement that the activity be “nonroutine stressful or strenuous physical.”

C. Summary disposition was improper because qualifying-activity questions remain factual

With its construction in hand, the Court applies summary-disposition standards (Pietsch v. Minn. Bd. of Chiropractic Exam’rs; Henson v. Uptown Drink, LLC). Because Groebner responded to multiple emergency calls (thus presumptively “nonroutine”) and because there is a triable question whether those responses involved the required “stressful physical” characteristics (informed by federal definitions), the Court agrees the ALJ erred by ending the case on summary disposition.

D. The 2016 presumption supplements rather than supplants Kramer/Johnson

The Court rejects the Commissioner’s attempt to make the presumption the exclusive route for heart-attack/stroke/vascular-rupture deaths. Treating “presumption” as a technical legal term (Cox v. Mid-Minn. Mut. Ins. Co.), and by analogy to other presumptions (Juntunen v. Carlton County; Hanson v. Dep’t of Nat. Res.), the Court holds that when the presumption fails or is rebutted, the claimant is not foreclosed—rather, the claimant may proceed under the ordinary line-of-duty standard. The Court further invokes the common-law non-abrogation canon (Zephier v. Agate) and finds no clear legislative intent to eliminate Kramer/Johnson.

3.3 Impact

• Lower threshold for “nonroutine” in emergency contexts: Agencies and adjudicators in Minnesota may no longer deny “nonroutine” status merely because a call type is common (e.g., domestics, traffic stops) or because an agency labels it “routine.” This aligns Minnesota with the federal program’s pro-claimant interpretive stance.
• Greater evidentiary focus on “stressful or strenuous physical”: Because “nonroutine” becomes presumptively satisfied by emergency response, litigation will likely concentrate on whether the officer’s activity was sufficiently “stressful” and “physical,” and on the medical causation/rebuttal battle.
• Two-track pathway to benefits: Claimants have (1) the statutory presumption route and, if it fails or is rebutted, (2) a Kramer/Johnson route requiring proof that death resulted in part from a specific instance of hazardous duty that exposed the officer to the hazard of being killed.
• Administrative adjudication consequences: ALJs must keep the presumption analysis distinct from Kramer/Johnson. The Court explicitly faults the ALJ for blending standards and for misusing Kramer/Johnson to define “nonroutine stressful or strenuous” under the presumption.
• Federal decisions are persuasive, not binding: Even though Minnesota’s interpretation is aligned with federal law, the Court cautions that a federal PSOB award does not bind the Commissioner’s Minnesota determination in a particular case—so factual development and Minnesota-specific adjudication remain important.

4. Complex Concepts Simplified

A. What is a “rebuttable presumption” here?

A rebuttable presumption is a legal shortcut. If the claimant proves the statute’s trigger facts (qualifying activity + timing + covered cause of death), the law assumes the death was line-of-duty unless the Commissioner overcomes that assumption with “competent medical evidence.” If the presumption is rebutted (or never triggered), the claimant can still try to prove line-of-duty causation the traditional way—here, under Kramer/Johnson.

B. What does “nonroutine” mean after this case?

It does not turn on whether the call type is common or whether the department calls it “routine.” If it is an emergency response, it is presumptively nonroutine. The real work then becomes whether the response was “stressful or strenuous physical.”

C. Why does it matter what the modifier applies to?

If “nonroutine stressful or strenuous physical” modified only “law enforcement,” then “other emergency response activity” could trigger the presumption without being nonroutine/stressful/physical—an outcome the Court rejects as inconsistent with grammar and statutory structure. After this decision, every listed activity must be “nonroutine stressful or strenuous physical” to qualify for the presumption.

D. The difference between the presumption and Kramer/Johnson

• Presumption track: Focuses on a defined 24-hour window and qualifying “nonroutine stressful or strenuous physical” duty/training; then burden shifts to the Commissioner to rebut medically.
• Kramer/Johnson track: Focuses on whether the death resulted in part from a specific instance of hazardous public safety duty that exposed the officer to being killed (not merely long-term job stress).

5. Conclusion

The Minnesota Supreme Court’s decision materially reshapes the practical administration of heart-related line-of-duty death claims. It (1) ties Minnesota’s “nonroutine” concept to the federal PSOB framework and makes emergency responses presumptively nonroutine regardless of frequency or labeling; (2) confirms that “nonroutine stressful or strenuous physical” is a universal qualifier across the statute’s list; and (3) preserves Kramer v. State, Peace Officers Ben. Fund and Johnson v. City of Plainview as an alternative path to proving “killed in the line of duty” when the presumption is unavailable or rebutted. On remand, the case proceeds to an evidentiary hearing where the factfinder must apply the presumption correctly and, if needed, evaluate causation under Kramer/Johnson.