Precedential Opinions
DECISIONS OF THE COURT OF APPEALS
FILED MONDAY, APRIL 20, 2026
A25-1408 State of Minnesota, Respondent, vs. Alexander Steven Jonas, Appellant.
Anoka County District Court, Hon. Melissa Saterbak.
When the court of appeals reverses a conviction and remands with instructions to vacate
that conviction and its sentence, the district court does not have authority to resentence on any other convictions absent express authority to do so.
Reversed and remanded; motion denied. Judge Peter M. Reyes, Jr.
A25-0736 State of Minnesota, Respondent, vs. Joseph William Finfrock, Appellant.
Hennepin County District Court, Hon. Judge Sarah Hudleston.
To determine whether an out-of-state offense is “in conformity with” a Minnesota offense
such that the out-of-state offense may be used to enhance a gross misdemenaor offense to a
felony under Minnesota Statutes section 609.3451, subdivision 3(b)(3) (2022), a district court
must determine whether the elements of the out-of-state offense would satisfy the elements of the Minnesota offense.
Affirmed in part, reversed in part, and remanded. Judge Jon Schmidt.
A25-1606, A25-1656 In the Matter of the Welfare of the Children of: L. P., Parent.
Clay County District Court, Hon. Leah duCharme.
If a child who is subject to a petition to terminate parental rights is an “Indian Child” as
defined under Minnesota Rule of Juvenile Protection 2.01(14) and Minnesota Statutes section
260.755, subdivision 8 (2024), then Minnesota Rule of Juvenile Protection 58.04(c)(3) requires
that the best interests of that child “be determined consistent” with the Indian Child Welfare Act (25 U.S.C. §§ 1901-63 (2018)) (ICWA). If the district court determines that the best-interests
requirements under ICWA are met, then the district court need not perform an analysis of the
best-interests factors that apply to non-Indian children under Minnesota Rule of Juvenile
Protection Procedure 58.04(c)(2)(ii).
Affirmed. Judge Jon Schmidt.