EN BANC CALENDAR
Before the Minnesota Supreme Court
April 2026
SUMMARY OF ISSUES
Summaries prepared by the Supreme Court Commissioner’s Office
Thursday, April 2, 2026
Supreme Court Courtroom, State Capitol Building, Second Floor
State of Minnesota, Respondent, vs. Jared James Sprowls, Appellant – Case No. A24-1584: Respondent State of Minnesota charged appellant Jared Sprowls with several offenses, including threats of violence-reckless disregard, in violation of Minn. Stat. § 609.713, subd. 1, and obstruction of legal process, in violation of Minn. Stat. § 609.50, subd. 1(2). Before trial, appellant filed a motion asking the district court to provide a voluntary-intoxication jury instruction for the charges of threats of violence-reckless disregard and obstruction of legal process. The district court denied appellant’s motion. After a trial, a jury found appellant guilty of all charges.
The court of appeals affirmed appellant’s convictions.
The supreme court granted review on the following issues: (1) whether “other state of mind” in Minn. Stat. § 609.075, the statute addressing the defense of voluntary intoxication, includes recklessness, and whether the district court erred by denying appellant’s request for a voluntary-intoxication jury instruction on the charge of threats of violence-reckless disregard; and (2) whether the district court erred by determining that obstruction of legal process was a general-intent crime, and that appellant was therefore not entitled to a voluntary-intoxication jury instruction. (Steele County)
State of Minnesota, Respondent, vs. Johnny Leroy Brown, Appellant – Case No. A25-0973: A Hennepin County grand jury indicted appellant Johnny Leroy Brown with several offenses, including first-degree murder while committing domestic abuse with a past pattern of domestic abuse. Brown pleaded not guilty and demanded a jury trial. Before trial, Brown filed a motion to exclude testimony from a domestic-violence expert witness, which was denied. During jury selection, Brown challenged the prosecutor’s use of a peremptory strike against a Black juror, alleging that the strike was based on race and that the prosecutor’s purported race-neutral explanations were pretextual. The district court denied the challenge. During the prosecutor’s closing argument, Brown objected to some of the statements made by the prosecutor. Without objection, the district court’s jury instructions did not include a specific unanimity instruction regarding the domestic-abuse element of the first-degree murder charge.
Brown’s brief presents the following issues: (1) whether the district court erred by denying Brown’s challenge to the State’s use of a peremptory strike against a Black juror because (a) Brown made a prima facie showing that the strike was based on race, and (b) Brown demonstrated the prosecutor’s purported race-neutral explanations were pretextual where the prosecutor engaged in disparate treatment of the Black juror versus similarly-situated non-Black jurors; (2) whether the district court abused its discretion by admitting unhelpful and unduly prejudicial expert testimony about domestic abuse where the testimony amounted to improper character evidence that heavily implied Brown killed the victim because he fit the profile of an abuser; (3) whether reversible error occurred where the prosecutor committed multiple instances of misconduct by vouching for the credibility of a witness, disparaging the defense, arguing facts not in evidence, and attacking Brown’s character; and (4) whether the district court plainly erred by failing to instruct the jurors they had to unanimously agree on the domestic-abuse element of the first-degree murder charge. (Hennepin County)
Tuesday, April 7, 2026
University of St. Thomas School of Law – Minneapolis, Minnesota
Kimberly Lowry, on behalf of herself and the Proposed Rule 23 Classes, et al., Plaintiffs (A24-0849), Respondents (A24-1910), vs. City of Minneapolis, Defendant (A24-0849), Respondent (A24-1910), Minneapolis Public Housing Authority, in and for the City of Minneapolis, et al. Defendants (A24-0849), Appellants (A24-1910) – Case Nos. A24-0849, A24-1910: The City of Minneapolis (“City”) has enacted ordinances that require rental dwellings to be licensed by the City. Rental dwelling licenses may only be issued after the City has conducted a code enforcement inspection and minimum licensing standards, including compliance with the City’s housing maintenance code, have been met. Issuance of a license, and the required annual renewal of the license, also requires payment of a licensing fee.
Appellant Minnesota Public Housing Authority (“MPHA”) is an independent authority created by resolution of the City. MPHA owns and/or manages thousands of residential units providing housing to City residents. MPHA receives most of its funding from the United States Department of Housing and Urban Development (“HUD”) and is subject to federal regulations setting forth minimum housing standards. To comply with HUD regulations, MPHA conducts inspections of the rental units in its properties. But the standards for, and focus of, the inspections MPHA conducts to comply with HUD regulations are different from the standards for and focus of inspections under the City’s code.
For decades, MPHA has not paid the City licensing fees, or obtained rental licenses from the City, for the dwellings it rents out. Pursuant to federal law, HUD is not permitted to provide contributions to support a low-income housing project, including MPHA, unless that project is “exempt from all real and personal property taxes levied or imposed by the State, city, county, or other political subdivision.” 42 U.S.C. § 1437d(d). Minnesota statutes accordingly provide that MPHA and its property “shall be exempt from all real and personal property taxes of the city, the county, the state, or any political subdivision thereof.” Minn. Stat. § 469.040, subd. 1. The City has entered into a cooperation agreement with MPHA providing that MPHA’s projects are exempt from real and personal property taxes and that MPHA will instead make annual payments in lieu of taxes for publicly provided services furnished from time to time. Historically, both HUD and the Minnesota State Auditor’s Office have questioned whether MPHA was required or permitted to pay rental licensing fees. And in a 1992 memorandum, a HUD representative informed the City and MPHA that under their interpretation of the law, MPHA was not allowed to pay the City’s rental licensing fees. Thereafter MPHA decided not to obtain rental licenses, and the City has not required MPHA to obtain licenses (nor conducted routine inspections of MPHA’s properties) ever since.
Respondents Kimberly Lowry and Jeanne Harris (collectively “Lowry”) sued the City and MPHA in September of 2021, purporting to represent a class of MPHA residents, and alleging that discriminatory conduct by the City and systematic inaction by the City and MPHA have led to MPHA residents living in substandard and dangerous conditions. She specifically alleges that MPHA is in violation of the City’s housing maintenance code because none of MPHA’s public-housing complexes are licensed and the City does not perform routine inspections of MPHA’s units; that MPHA violated the implied covenants of habitability in Minn. Stat. § 504B.161; and that the City’s failure to inspect MPHA properties constitutes discrimination under the Minnesota Human Rights Act. (Only the claims against MPHA are at issue in the appeal before the supreme court.) Lowry seeks, among other things, damages for the poor condition of the housing, along with injunctive relief including disgorgement of all rent paid for unlicensed properties for the six-year period of the statute of limitations.
MPHA moved for partial summary judgment, arguing that it is entitled to discretionary, official, and sovereign immunity from Lowry’s claims seeking monetary relief. The district court granted MPHA’s motion. It concluded that MPHA was immune from Lowry’s claims for violation of the implied covenants of habitability under the doctrine of sovereign immunity. It likewise concluded that MPHA’s decision not to apply for rental licenses was protected by discretionary and official immunity. And the district court concluded that some of Lowry’s claims were based on impermissible “speculation” that the lack of licenses led to Lowry’s damages.
The court of appeals reversed and remanded for further proceedings. With respect to sovereign immunity, the court concluded that the statutory implied covenants of habitability are contract claims, which are not generally subject to immunity; and that in any event, that the Legislature intended to abolish sovereign immunity for city-run public-housing authorities. The court of appeals likewise concluded that neither discretionary nor official immunity applied. It concluded that MPHA was not performing a “discretionary function or duty” when it chose not to seek licenses, but was instead simply failing to follow the law. It rejected MPHA’s argument that, because it is exempt from paying taxes under Minn. Stat. § 469.040, subd. 1, it cannot legally be required to obtain a license and obtain a license fee; instead, the court of appeals concluded that license fees are not taxes, and that if MPHA were immune from payment of a fee, it could “obtain a license from the city . . . without paying a fee.” The court of appeals concluded that the 1992 memorandum from HUD did not have the force of law that would be necessary to preempt the City’s ordinances, and it interpreted the memorandum as not requiring MPHA to “sidestep the licensing process altogether.” Finally, the court of appeals concluded that there were questions of material fact as to whether enforcement of the licensing requirements would have led to Lowry’s alleged injuries.
The supreme court granted review of the following issues: (1) whether MPHA is exempt from purchasing rental licenses where its federal regulator, HUD, barred it from doing so and where Minnesota Statute section 469.040, subd. 1, limits the fees cities can charge public housing authorities to services that provide a direct physical benefit to the property; (2) whether the decision not to purchase licenses was protected by discretionary immunity and official immunity where MPHA complied with its federal regulator’s directive not to purchase licenses; (3) whether MPHA can be held liable for not “obtaining” licenses without paying for them; and (4) whether MPHA can be held liable for damages merely because it did not have licenses, even though the mere absence of licenses did not cause articulable damage to Plaintiffs and Plaintiffs still received the benefit of public housing. (Hennepin County)