Minnesota Supreme Court Opinions: December 17, 2025

Today’s edition of Minnesota Appellate Court Watch covers the single opinion released by the Minnesota Supreme Court on December 17, 2025. All we have is one attorney discipline matter; no other decisions. There is a Special Term Conference on the Court’s calendar for today, which means we’ll likely see orders on pending petitions for review released tomorrow. Those PFR orders will be covered in next week’s oh-so-jolly Christmas Eve edition of Minn. App. Ct. Watch.

Besides that, we’re in a relatively quiet period for our appellate courts. The Supreme Court has no oral arguments scheduled until January 5, 2026. It’s possible we could see opinions released on December 24, as it’s not technically a court holiday. However, I wouldn’t count on a night-before-Christmas blockbuster. And after tomorrow, the Court of Appeals gets a rare reprieve from arguments until December 30. I hope the last panel out the door—likely Judges Bentley, Bratvold, and Schmidt—leave a faucet dripping and put a peppermint stick out in case Santa Claus swings by the Judicial Center.

 This newsletter contains the sole opinions of me, Daniel Suitor. You can reach me via email at opinions[at]minnappct[dot]watch. As always, everything contained here is solely for informational purposes, and is not legal advice. This newsletter is not a solicitation for my services. If you have a legal issue, you should contact your local public defender’s office, legal aid provider, or a private attorney.

In re Petition for Disciplinary Action against Hacklander

As I discussed last week, I try to be circumspect when writing about attorney discipline. There’s a balance between gawking and considering the good of the legal profession. My lodestone is, as ever: there are often difficult personal circumstances underlying discipline-worthy conduct and this does not excuse the violation of our ethical obligations, but neither does it excuse our moral imperative to view attorneys as whole people.

Citation: In re Petition for Disciplinary Action against Hacklander, No. A25-0064 (Minn. Dec. 9, 2025).

• Attorney Discipline
• Original Jurisdiction
• Opinion, Moore, III
• OLPR’s Petition

Case Statistics

• Petition filed: 1/13/2025 (330 days from petition to decision)
• Argued: No argument, order issued after joint stipulation and recommendation by OLPR and respondent and independent review of record

Case Summary
This disciplinary matter arises from allegations of attorney misconduct in a family law matter. The respondent represented a husband in a dissolution, which was granted in 2021. In 2023, the parties engaged in mediation to resolve disputes related to the minor children at issue in the case.

A mediation agreement was reached on October 27, 2023. That day, Respondent presented a proposed stipulation and order to the wife’s attorney. On October 30, 2023, the wife’s attorney indicated she did not agree with the proposed document. Two days later, Respondent urged opposing counsel to file the proposed document as is. Two more days later, on November 3, 2023, opposing counsel informed Respondent that it may take until the next week to turn the document around. On November 7 and 8, Respondent urged opposing counsel to execute and file the documents, including an email reading “Please file this right away" and with the same document from his last email attached.

Then, on November 13, 2023, Respondent left opposing counsel a voicemail that included the following statement:

“I’m not sure what’s going on but if something doesn’t get filed by four o’clock today, then I’m just going to go ahead and file my version with just our signatures . . . .”

Without hearing from opposing counsel, Respondent seemingly filed the October 27 version of the proposed stipulation and order, which opposing counsel had not agreed to. Respondent put opposing counsel’s /s/ electronic signature on the document with the heading “APPROVED AS TO FORM.”

The next day, opposing counsel emailed Respondent requesting he take remedial action. Respondent “refused to take any remedial action and, instead, instructed [opposing counsel] to file whatever she deemed appropriate for the circumstances.”

Ultimately, OLPR and Respondent entered into a stipulation recommending a public reprimand, with OLPR pointing to Respondents “recent, significant pro bono services, acceptance of responsibility, and genuine remorse.” Moreover, Respondent had practiced for 27 years before this incident with only one disciplinary finding, a private admonition. The Supreme Court reviewed the record and agreed, entering its judgment for a public reprimand for making a false statement to a court.

From start to violation, 17 days elapsed. While I have not practiced family law, my landlord-tenant work helps me understand how difficult certain highly adversarial, hand-to-hand, high-touch practices can be. And I can’t speak to the underlying issues in the case, whether this level of urgency was appropriate or not. But November 3, 2023, was a Friday. By the next Tuesday and Wednesday, Respondent was repeatedly emailing opposing counsel. And he committed his violation the following Monday. It seems likely that some patience was warranted here.

It is heartening to see an experienced attorney accept responsibility rather than dig in. We’ve probably all needed a slight shock to our system to recenter ourselves in our practices, from time to time. I wish Respondent well. But this does lead us to add a new rule to our to our running list of The Rules of Law:

Rule #2 of Attorney Misconduct: Don't leave another attorney a voicemail stating that you intend to commit attorney misconduct later that day if that attorney doesn't do what you want.

Miscellanea

Banner image courtesy of the inestimable Tony Webster.

Out of candor to readers, my standing disclosures and conflicts are listed at the bottom of this page. I will disclose if I have worked on a case in a formal capacity, had any informal contacts with the case, or have personal connections to the case. I do this because I think transparency about my background helps readers judge my writing properly.