In the Matter of a Public Safety Officer Death Benefit for Eric William Groebner (Deceased), A241410

Background

Eric Groebner, an Anoka patrol officer, worked a 12-hour shift on September 13, 2022, responding to 11 calls, and died the next day from a vascular rupture. 1
His widow sought Minnesota line-of-duty death benefits, but the Commissioner denied the claim and an ALJ granted summary disposition for the Commissioner. 2
The court of appeals reversed, holding that factual disputes remained and that Kramer and Johnson did not control heart-related deaths under the amended statute. 3
The Minnesota Supreme Court granted review to decide the meaning of "nonroutine" and whether the 2016 presumption displaced Kramer and Johnson. 4
The court described the 2016 amendment as adding a rebuttable presumption for certain heart-related deaths if the officer engaged in nonroutine stressful or strenuous physical emergency activity within 24 hours. 5
Groebner had responded to several emergency and domestic calls during the shift, including a domestic call involving a child with a knife and a speeding vehicle stop. 6

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Meaning of "nonroutine" under the presumption statute 7	Groebner: means not customary or regularly performed.	Commissioner: means special or extraordinary.	Ambiguous; construed to mean emergency calls are presumptively nonroutine. 8
Scope of "nonroutine stressful or strenuous physical" phrase 9	Groebner: modifies only law enforcement.	Commissioner: modifies the whole series.	Modifies the entire series of listed activities. 10
Whether presumption displaced Kramer and Johnson 11	Groebner: if presumption fails or is rebutted, estate may still prove line-of-duty death under Kramer and Johnson.	Commissioner: heart-related deaths qualify only through the presumption.	Presumption is rebuttable and Kramer and Johnson still apply if presumption is unavailable or rebutted. 12
Summary disposition on Groebner's shift 13	Groebner: evidence creates fact issue on qualifying emergency activity.	Commissioner: no nonroutine stressful or strenuous physical activity as a matter of law.	Genuine fact issue exists; summary disposition was improper. 14

Key Cases Cited

Kramer v. State, Peace Officers Benefit Fund, 380 N.W.2d 497 (Minn. 1986) (defines line-of-duty death as death from duties peculiar to a peace officer exposing the officer to risk of being killed 15)
Johnson v. City of Plainview, 431 N.W.2d 109 (Minn. 1988) (applies Kramer to fatal heart-related incidents during hazardous firefighting duties 16)
Pietsch v. Minnesota Board of Chiropractic Examiners, 683 N.W.2d 303 (Minn. 2004) (summary disposition is reviewed like summary judgment and statutory interpretation is de novo 17)
Rodriguez v. State Farm Mutual Automobile Insurance Co., 931 N.W.2d 632 (Minn. 2019) (plain statutory language controls if clear 18)
In re Welfare of J.B., 782 N.W.2d 535 (Minn. 2010) (a statute is ambiguous when reasonably susceptible to more than one interpretation 19)
State v. Khalil, 956 N.W.2d 627 (Minn. 2021) (series-qualifier rule generally applies a modifier to an entire parallel list 20)
Cox v. Mid-Minnesota Mutual Insurance Co., 909 N.W.2d 540 (Minn. 2018) (legal terms with settled meaning are construed according to that special meaning 21)
Juntunen v. Carlton County, 982 N.W.2d 729 (Minn. 2022) (a claimant may still pursue benefits after a statutory presumption fails or is rebutted 22)
Hanson v. Department of Natural Resources, 972 N.W.2d 362 (Minn. 2022) (illustrates burden-shifting where rebuttal returns the burden to the claimant 23)
Zephier v. Agate, 957 N.W.2d 866 (Minn. 2021) (courts presume statutes do not abrogate common law absent clear legislative intent 24)