Supreme Court Digest: Oct. 22, 2025

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Civil

Civil Rights

Sexual Orientation

Appellant brought this transgender discrimination case against respondent raising claims exclusively under the Minnesota Human Rights Act (MHRA). Both parties agree that the Legislature has spoken clearly and that the MHRA prohibits discrimination based upon transgender status. The issue in this case was whether, under the MHRA’s prohibitions on discrimination in business and in public accommodations, respondent’s express prohibition on transgender women competing in the women’s division of a powerlifting competition violated the MHRA. The District Court granted appellant’s motion for partial summary judgment on liability as to the claim of discrimination in public accommodations on the basis of sexual orientation and as to the claim of business discrimination on the basis of sexual orientation and sex. The Court of Appeals reversed, concluding that there were genuine issues of material fact precluding partial summary judgment on both the business and public accommodation discrimination claims.

The Supreme Court held that (1) under the MHRA’s protection of transgender individuals against discrimination based on sexual orientation, Minn. Stat. § 363A.03, subd. 44 (2018), a policy that expressly prohibits transgender women from competing in the women’s division of a powerlifting competition is facially discriminatory and constitutes direct evidence of discrimination based on sexual orientation under the MHRA’s prohibition against business discrimination and discrimination by places of public accommodation, found at Minn. Stat. §§ 363A.11, 363A.17 (2018); (2) there was a genuine dispute of material fact as to whether seeking to ensure competitive fairness in an athletic competition satisfies the legitimate business purpose defense for sexual orientation and sex discrimination in business under Minn. Stat. § 363A.17 (2018) of the MHRA that forecloses partial summary judgment for the plaintiff as to liability on this claim; (3) in the absence of any alleged statutory exemption or defense, the District Court properly granted partial summary judgment for the plaintiff on the claim of sexual orientation discrimination in public accommodations; (4) the holding in Goins v. West Group, 635 N.W.2d 717 (Minn. 2001), is limited to claims of sexual orientation discrimination under the MHRA related to employment. Affirmed in part, reversed in part, and remanded.

A23-0373, A23-0621 Cooper v. USA Powerlifting (Court of Appeals)

Workers’ Compensation

Recreational Programs

Employee, a middle school teacher at a Minneapolis public school, injured her knee while playing basketball with students during an afterschool basketball practice. She sought workers’ compensation benefits, but the self-insured employer denied liability. The employee filed a claim petition seeking benefits. Following an administrative hearing on her claim petition, a compensation judge determined that the employee’s claim was compensable, concluding that the injury arose out of and in the course of the employee’s employment and that the exclusion under Minn. Stat. § 176.021, subd. 9, for “[i]njuries incurred while participating in voluntary recreational programs sponsored by the employer,” did not apply. The employer appealed to the Workers’ Compensation Court of Appeals (WCCA), arguing that the employee’s injury did not occur “in the course of” employment and that § 176.021, subd. 9, excluded compensation benefits because the injury occurred during a voluntary employer-sponsored recreational program. The WCCA affirmed.

The Supreme Court held that (1) employee’s injury occurred “in the course of” employment for the purpose of § 176.021, subd. 1, because the undisputed facts show that employee sustained the injury within an hour of the end of the workday, the injury occurred at the workplace, and employee was engaged in employment-related activity; and (2) § 176.021, subd. 9, which excludes from workers’ compensation liability injuries that occur while an employee is participating in a voluntary employer-sponsored recreational program, applies only to employer programs that are for the benefit of employees. Affirmed.

A25-0193 Lindsay v. Minneapolis Pub. School Dist. (Workers’ Compensation Court of Appeals)

Criminal

Search Warrants

Probable Cause

At issue in this case was whether there is an independent requirement that a tip from a confidential reliable informant be corroborated to establish probable cause for a search warrant. In a controlled substance crime case, defendant moved to suppress the evidence found in a search of her house pursuant to a warrant. The warrant application stated that a confidential reliable informant had personally observed people smoking methamphetamine in defendant’s house sometime in the 72 hours prior to the warrant application. Concluding that the warrant application established probable cause, the District Court denied the suppression motion, and defendant was found guilty after a jury trial. On appeal, defendant challenged the District Court’s denial of her suppression motion. In a divided opinion, the Court of Appeals affirmed the District Court, concluding that the totality of the circumstances established probable cause that drugs would be found in defendant’s house at the time of the search. The Court of Appeals rejected defendant’s argument that a tip must always be corroborated to establish probable cause.

The Supreme Court held that (1) when determining whether a search warrant is supported by probable cause, the District Court must consider corroboration of a confidential reliable informant’s tip in considering the totality of the circumstances, but corroboration is not an independent requirement; and (2) the search warrant in this case was not supported by probable cause because the limited, uncorroborated information in the warrant application did not establish a fair probability that contraband or evidence of a crime would be found in defendant’s house. Reversed and remanded.

A23-0927 State v. Nagle (Court of Appeals)

Sentencing

Motions to Correct

Defendant was convicted of three counts of first-degree murder and three counts of second-degree murder in 1995 and was sentenced to three consecutive life sentences. After his convictions were affirmed on direct appeal in 1997, he filed several postconviction petitions, which were denied. In July 2024, defendant filed his fifth request for postconviction relief—a motion to correct or reduce his sentence under Minn. R. Crim. P. 27.03, subd. 9. In his motion, defendant argued that his sentence was unlawful because he did not receive a presentence investigation (PSI), which would have revealed that he has dyslexia and a history of childhood physical abuse, and because the District Court miscalculated and improperly weighed his criminal history score. The State asserted that defendant’s motion was really a petition for postconviction relief under Minn. Stat. § 590.01. Based on that assertion, the State argued defendant’s claims were time-barred under Minn. Stat. § 590.01, subd. 4, and then erroneously cited State v. Knaffla, 243 N.W.2d 737 (Minn. 1976), for the proposition that the statutory time bar is jurisdictional. The District Court agreed with the State and denied defendant’s motion for relief.

The Supreme Court held that (1) the District Court erred in concluding it lacked jurisdiction to hear defendant’s motion to correct a sentence, which only challenged the lawfulness of his mandatory life sentences, because under Reynolds v. State, 888 N.W.2d 125 (Minn. 2016), such a motion is not subject to the limitations period imposed by Minn. Stat. § 590.01, subd. 4, and even if it were, under Carlton v. State, 816 N.W.2d 590 (Minn. 2012), the limitations period imposed by § 590.01, subdivision 4 is not jurisdictional; and (2) although the District Court erred when it concluded that it lacked jurisdiction, it reached the correct outcome in this case because defendant was sentenced to statutorily mandated life sentences for first-degree murder, and therefore the absence of a presentence investigation, as well as the alleged miscalculation and improper weighing of his criminal history score, did not render his sentences unlawful within the meaning of Minn. R. Crim. P. 27.03, subd. 9 because the presentence investigation statute and the sentencing guidelines do not govern mandatory life imprisonment sentences for first-degree murder. Affirmed.

A24-1702 Riley v. State (Carver County)