Minnesota Supreme Court Opinions: December 31, 2025

Daniel Suitor

Daniel Suitor

— 4 min read
Minnesota Supreme Court Opinions: December 31, 2025

Today’s edition of Minnesota Appellate Court Watch covers the opinion released by the Minnesota Supreme Court on December 31, 2025. I'm celebrating the New Year with my family,* so this week's writeup will be brief.

* Daycare is closed and we're all recovering from various stages of this year's nasty variant of the flu.

Congratulations to everyone who made it through 2025, an extremely normal and chill year for all involved. If you didn't make it, well, I'm sure you gave it your best try. On a personal note: thank you for reading this odd little project of mine. It's been fun to hear from people who find MACW useful or amusing. I wish everyone a Happy New Year.

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.

Walsh v. City of Orono

Citation: Walsh v. City of Orono, No. A25-0354 (Minn. Dec. 31, 2025).

  • Civil: Election Law
  • Appeal from Hennepin County District Court (27-CV-25-2808)
  • 12/31 Opinion, Chief Justice Hudson
  • 5/9 Order, Chief Justice Hudson

Procedural Note
This case was filed on March 4, 2025, and the next day counsel for the appellant filed a Petition for Accelerated Review, supported in outcome but not reasoning by the respondents, seeking to bypass the Court of Appeals and go straight to the Supreme Court. Given the time-sensitive nature of the case, involving a special election scheduled for May 13, the Supreme Court granted that petition a week later, and the case was argued almost exactly two months from filing, on May 6. An order affirming the district court was issued three days later, on May 9, permitting the election to go forward four days later.

Case Statistics

  • Petition for Accelerated Review requested: 3/5/2025 (65 days from PAR request to decision, 301 days from PAR request to opinion)
  • PAR Granted: 3/12/2025 (7 days from PAR request to grant, 58 days from PAR grant to decision, 294 days from PAR grant to opinion)
  • Argued: 5/06/2025 (55 days from PAR grant to argument, 3 days from argument to decision, 239 days from argument to opinion)

Rulings

  1. The claims in the petition filed before the district court under Minnesota Statutes section 204B.44 fall within the scope of that statute because the claims allege errors involving respondents’ duties concerning a specific election.
  2. Minnesota Statutes section 412.02, subdivision 2a, authorizes a statutory city to call for a special election to fill a city council vacancy before the next regular city election based on a special-election ordinance enacted after a person was initially appointed to fill the vacancy.
  3. A statutory city does not violate article VIII, section 5, of the Minnesota Constitution regarding the removal of inferior officers when it calls for a special election to fill a city council seat vacated by a sitting councilmember’s resignation.

Upcoming Oral Arguments

Monday, January 5

Knapp v. Commissioner of Public Safety, No. A24-1440

Issue granted:

  • Whether the party offering the results of a chemical or scientific breath test into evidence in an implied consent hearing has the burden to show a proper observation period when establishing a prima facie case that the test is reliable and that its administration conformed to procedure necessary to ensure reliability

CVC Investments LLP v. State Farm Fire and Casualty Co., No. A24-1915

Issues granted:

  • Can a party create a justiciable controversy by requesting a tolling agreement and then filing the action before the other party responds based on an alleged “future” breach?
  • Whether a justiciable controversy exists prior to one party expressly declaring a controversy exists under a contract under Minn. Stat. Ch. 555 and contract law

Tuesday, January 6

Wredberg v. Canvas Health, Inc., No. A24-1897

Issues granted:

  • Where Minn. Stat. § 595.02 subd. 1(k) prohibits sexual-assault counselors from disclosing “any opinion or information received from or about the victim without the victim’s consent,” does a sexual-assault counselor terminated for refusing to disclose victim information, “without the victim’s consent,” upon her employer’s demand for the information to provide to non-counselors in and outside the workplace, have a claim under the Minnesota Whistleblower Act?
  • Where Minn. Stat. § 595.02 subd. 1(k) prohibits sexual-assault counselors from disclosing “any opinion or information received from or about the victim without the victim’s consent,” does a sexual-assault counselor terminated for refusing to disclose victim information “without the victim’s consent,” upon her employer’s demand for the information to provide to non-counselors in and outside the workplace, have a claim for wrongful discharge in violation of public policy?

Wednesday, January 7

State v. Bucholz, No. A25-0518

  • Criminal
  • Appeal from
  • No Court of Appeals opinion; appeal of first-degree murder conviction taken directly from district court as allowed by statute

Issues:

  • Whether the district court denied Bucholz his constitutional right to present a complete defense, and committed reversible error, by prohibiting him from introducing alternative-perpetrator evidence at his trial
  • Whether the district court erred by convicting Bucholz of both first-degree and the included offense of second-degree murder

Cook v. Trimble, No. A24-1486

Issues granted:

  • Should a litigant be able to assert a claim for invasion-of-privacy against their opponent’s lawyers based on the filing of an opposition to a motion in limine?
  • Did the court of appeals err in concluding that the judicial-proceedings privilege barred Cook from asserting a defamation claim relating to the attorneys’ misconduct?

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.

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