Minnesota Supreme Court Opinions: December 24, 2025

Daniel Suitor

24 Dec 2025 — 7 min read

Today’s edition of Minnesota Appellate Court Watch covers the opinions released by the Minnesota Supreme Court on December 24, 2025. We have two opinions this week, but my son's daycare is closed and we're off to spend Christmas Eve at the zoo. So I've forgone my longer writeups for brief capsules today. But in their stead, there's a bit of holiday merriment to enjoy.

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.

A Visit from St. Nicholas, Esq.

Adapted from the original poem by Clement Clarke Moore

‘Twas the night before Christmas, when all through the Court
Not a lawyer was stirring, not even a clerk;
The draft opinions were submitted for citechecks with care,
In hopes that wise rulings soon would be there;
The counsel were nestled all snug in their beds;
While outlines of arguments danced in their heads;
And my bench memo submitted, and my edits all done,
I’d just set my out-of-office with the appropriate tone,
When out on the Capital Mall there arose such a clatter,
I sprang from my desk to see what was the matter.
Away to the window I flew like a flash,
Raised up the blinds and threw up the sash.
The light of the moon on the two-week-old snow,
Gave a lustre of midday to proceedings below,
When what to my caffeine-aided eyes did appear,
But an appellate panel and eight judges to hear,
With a little presiding judge so lively and quick,
I knew in a moment he must be St. Nick.
More rapid than lunch orders his judges they came,
And he whistled, and shouted, and called them by name:
“Now, Harris! now, Bentley! now Gaïtas and Larson!
On, Bjorkman! on, Bratvold! on, Hudson and Thissen!
To the top of the Judicial Center! to the end of the Mall!
Now dash away! dash away! dash away all!”
And then, in a twinkling, I heard on the roof
The judges all clattering around in their boots.
As I rushed down the hallway and came the corner around,
Into chambers St. Nicholas came with a bound.
He was dressed in fur robes, from his head to his foot,
The judges came too, robes covered in ash and soot;
With bundles of toys flung over their backs,

They came to decide what should stay in the sacks.
Here to adjudicate the case of Naughty v. Nice,
The panel took their seats, seeming cold as ice.
Two elves did appear, to argue positions,
Santa’s annual panel thus began to listen.
‘Twas not long before questions did fly,
This last-minute appeal seemed do-or-die.
Soon the sound faded of the final rebuttal,
And St. Nick gathered his judges in one final huddle;
As I hid in the gallery, hoping to overhear,
Whether this last-minute petition would meet smile or sneer.
In just a short time Santa announced their decision,
A unanimous choice, there would be no division:
On this night, all were adjudicated “Nice,”
And when Santa dismissed them, no one thought twice,
The judges all scattered, the elf advocates too,
With just St. Nick remaining, I did not know what to do.
I thought to sneak out and rush home quite spry,
But as I crept towards the door, Santa caught my eye.
With a wink and a nod, he allayed my fears,
For what is any ruling if it reaches no ears?
And with that he rushed from the court without warning,
There were gifts yet to deliver before morning,
And quicker than possible I heard sleighbells ring,
Then saw the man and his sled take off on a wing.
I wondered whether I could trust my own story,
Who would believe me? They’d find my tale hoary.
But Santa made one last pronouncement that settled my plight:
“Happy Christmas to all, and to all a good night!”

State v. Douglas

Citation: State v. Douglas, No. A24-0385 (Minn. Dec. 24, 2025).

Criminal:
Appeal from Scott County District Court (70-CR-19-18076)
Opinion, Thissen (Procaccini dissenting)

Case Statistics

PFR Requested: 10/23/2024 (427 days from PFR request to decision)
PFR Granted: 12/17/2024 (55 days from PFR request to grant, 372 days from PFR grant to decision)
Argued: 4/03/2025 (107 days from PFR grant to argument, 265 days from argument to decision)

Ruling
The good-faith exception to the exclusionary rule does not apply to a warrantless vehicle search based solely on the smell of marijuana that occurred before we issued our opinion in State v. Torgerson, 995 N.W.2d 164 (Minn. 2023), which held that the odor of 1 marijuana alone is insufficient to create probable cause to search a vehicle under the automobile exception to the warrant requirement.

Thigpen v. Best Home Care LLC

"Citation: Thigpen v. Best Home Care LLC, No. A23-1544 (Minn. Dec. 24, 2025).

Civil: Unemployment
Appeal from DEED District Court (Nos. 48894042-5, 49097671-4, 48681520-5, 49097672-4 )
Opinion, Moore, III

Case Statistics

PFR Requested: 8/28/2024 (483 days from PFR request to decision)
PFR Granted: 11/27/2024 (91 days from PFR request to grant, 392 days from PFR grant to decision)
Argued: 3/03/2025 (96 days from PFR grant to argument, 296 days from argument to decision)

Ruling
The penalty under Minnesota law for obtaining unemployment benefit overpayments through misrepresentation, set forth in Minn. Stat. § 268.18, subd. 2, does not violate the Excessive Fines Clauses of the United States and Minnesota Constitutions.

In re Petition for Disciplinary Action against Peters

"Citation: In re Petition for Disciplinary Action against Peters, No. A24-1984 (Minn. Dec. 17, 2025).

Attorney Discipline:
Appeal from Original Jurisdiction District Court
Opinion, Moore, III
OLPR Petition

Reinstated without further opinion.

Orders on Petitions for Review

Average PFR decision time for PFR orders released December 17, 2025

All Decisions: 58 days
All Grants: 59 days
Straight Grants: 84 days
Granted/Stayed: 50 days
Denials: 58 days
Civil: 59 days
Criminal: 58 days
Certiorari: 50 days
Writs: 56 days

Grants
Grant v. State, No. A24-1908, Criminal: Postconviction Relief, Appeal from Hennepin County District Court (27-CR-13-22246), 84 days from PFR request to decision

Issues Granted: Whether the Act of May 19, 2023, requires a district court to hold an evidentiary hearing before determining whether the petitioner established by a preponderance of the evidence that he is entitled relief?

In re Denial of Duty Death Benefits for Floyd Jones, No. A25-0443, Certiorari: Death Benefits, Appeal from Court of Administrative Hearings (OAH 5-2400-40160), 50 days from PFR request to decision

Granted and Stayed pending final disposition in In re Public Safety Officer Death Benefit for Groebner, A24-1410

State v. Hardy, No. A24-1724, Criminal, Appeal from Itasca County District Court (31-CR-22-2822), 43 days from PFR request to decision

Granted and Stayed pending final disposition in State v. Firkus, A23-0973

State v. Jones, No. A24-1976 , Criminal, Appeal from Ramsey County District Court (62-CR-24-31), 58 days from PFR request to decision

Granted and Stayed pending final disposition in State v. Firkus, A23-0973

Denials

Abdi v. Melchoir, No. A25-0648, Civil: Personal Injury, Appeal from Hennepin County District Court (27-CV-23-16658), 57 days from PFR request to decision
Cass County v. Aho, No. A25-0492, Civil: Land Use, Appeal from Cass County District Court (11-CV-24-1083), 48 days from PFR request to decision
In re Moore, No. A25-1578, Writ: Prohibition, Case below in Ramsey County District Court (62-MH-PR-25-269), 56 days from PFR request to decision
Dingmann v. Bassford Remele PA, No. A25-1346, Writ: Mandamus, Case below in Stearns County District Court (73-CV-25-5356), 56 days from PFR request to decision
In re Estate of Cooper, No. A24-1835, Civil: Estates and Trusts, Appeal from Ramsey County District Court (62-PR-23-154 ), 76 days from PFR request to decision
In re Scheffler, No. A25-1275, Writ: Prohibition, Original Jurisdiction, 55 days from PFR request to decision
In re Civil Commitment of Opiacha, No. A25-1258, Civil: Civil Commitment, Appeal from Hennepin County District Court (27-MH-PR-13-906), 51 days from PFR request to decision
In re Civil Commitment of Allan, No. A25-0652, Civil: Civil Commitment, Appeal from Otter Tail County District Court (56-PR-07-3493 ), 48 days from PFR request to decision
In re Welfare of C.L.B., No. A25-0353, Criminal: Juvenile, Appeal from Hennepin County District Court (27-JV-24-1915), 49 days from PFR request to decision
Haik v. Professional Educator Licensing and Standards Board, No. A25-0368, Civil: Professional Licensing, Appeal from Ramsey County District Court (62-CV-24-6488), 51 days from PFR request to decision
Holper v. City of Gilman, No. A25-0075, Civil: Personal Injury, Appeal from Benton County District Court (05-CV-24-19 ), 76 days from PFR request to decision
State v. Sledge, No. A25-1447, Criminal: Traffic, Appeal from Hennepin County District Court (27-VB-24-76680), 48 days from PFR request to decision
State v. Banks, No. A24-1728, Criminal, Appeal from Clay County District Court (14-CR-23-2786 ), 56 days from PFR request to decision
State v. Fohrenkam, No. A25-0183, Criminal, Appeal from Hennepin County District Court (27-CR-22-3336 ), 56 days from PFR request to decision
State v. Oelrich, No. A24-2008, Criminal: Sentencing, Appeal from Pine County District Court (58-CR-23-174), 56 days from PFR request to decision
State v. Halling, No. A24-1531, Criminal, Appeal from Wright County District Court (86-CR-22-4688), 76 days from PFR request to decision
State v. Carreno, No. A25-0488, Criminal, Appeal from Kandiyohi County District Court (34-CR-24-653), 35 days from PFR request to decision
State v. Hall, No. A24-1201, Criminal, Appeal from Redwood County District Court (64-CR-21-99 ), 62 days from PFR request to decision
State v. Burrell, No. A25-0007, Criminal, Appeal from Hennepin County District Court (27-CR-23-18680 ), 70 days from PFR request to decision
Bernard v. Superset Tile & Stone, LLC, No. A24-1770, Civil: Employment, Appeal from Hennepin County District Court (27-CV-22-9968 ), 70 days from PFR request to decision
Oman vs. Sharei Chesed Congregation, No. A25-0096, Civil, Appeal from Hennepin County District Court (27-CV-23-6010 ), 57 days from PFR request to decision
State v. Khalid, No. A24-1595, Criminal, Appeal from Sherburne County District Court (71-CR-23-1302), 59 days from PFR request to decision
State v. Davis, No. A24-1042, Criminal: , Appeal from Blue Earth County District Court (07-CR-22-3197), 58 days from PFR request to decision
Engebretson v. Northern Tool and Equipment Company, Inc., No. A24-2027, Civil: Discrimination, Appeal from Dakota County District Court (19HA-CV-20-3022), 58 days from PFR request to decision