Cited by
Opinions in Minnesota that cite Dunham v. Roer, 708 N.W.2d 552.
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Jenna Flick Susko v. Jacob Lee Wilson
Minn. Ct. App. 2026
A party seeking an HRO must show (1) “objectively unreasonable conduct or intent on the part of the harasser” and (2) an objectively reasonable belief by the object of the harassing conduct that he or she was being “subject[ed] to harassing conduct.” rev. denied (Minn. Mar.
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Kaylee Anne Vartanian OBO Elena Jo Vartanian-Dixon v. Hillary Anne Laska
Minn. Ct. App. 2026
4 rev. denied (Minn. Mar.
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Charles Thomas Marhula v. Lynn Eaton
Minn. Ct. App. 2026
1(a)(1) ( 2024) (emphasis added); see also Dunham v. Roer , (stating that harassment requires “ repeated intrusive or unwanted acts, words, or gestures”), rev. denied (Minn. Mar.
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Calder Perth Rasmusson and On Behalf of Minor Child(ren) v. Renae Marie Gielen
Minn. Ct. App. 2026
There must be “an objectively reasonable belief on the part of the person subject to harassing conduct.” rev. denied (Minn. Mar.
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Mai Lia Xiong v. Derick James Davis
Minn. Ct. App. 2026
First, Davis’s free-speech argument is inconsistent with this court’s rev. denied (Minn. Mar.
- Gary Lee Ambrose v. Shea Jerred Nettifee (A25-1601), Idlelee Renee Ambrose, vs. Shea Jerred Nettifee (A25-1602) Minn. Ct. App. 2026
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Gary Lee Ambrose v. Shea Jerred Nettifee (A25-1601), Idlelee Renee Ambrose, vs. Shea Jerred Nettifee (A25-1602)
Minn. Ct. App. 2026
We have held that regulation of conduct constituting “harassment” under Minnesota Statutes section 609.748 is not unconstitutional because the statute “only regulates speech or conduct that constitutes ‘fighting words,’ ‘true threats,’ or substantial invasions of one’s privacy.” rev. denied (Minn. Mar.
- Benita M Brannon v. John Sterling Howe Minn. Ct. App. 2026
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Benita M Brannon v. John Sterling Howe
Minn. Ct. App. 2026
The HRO statute “requires both objectively unreasonable conduct or intent on the part of the harasser and an objectively reasonable belief on the part of the person subject to harassing conduct.” rev. denied (Minn. Mar.
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Krystal Maria Drift v. Sean Michael Swapinski
Minn. Ct. App. 2026
–67 (Minn. App. 2006), rev. denied (Minn. Mar.
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Peter Richard Rickmyer, Appellant, vs. Xenos Letoi Brooks, R e s pondent.
Minn. Ct. App. 2026
Harassment under section 609.748 “does not depend entirely on whether the ‘target’ suffers adverse effects.” Dunham v. Roer , rev. denied (Minn. Mar.
- Cole Marie Carlson v. Cory Ross Holte Minn. Ct. App. 2025
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Cole Marie Carlson v. Cory Ross Holte
Minn. Ct. App. 2025
The HRO statute “requires both objectively unreasonable conduct or intent on the part of the harasser and an objectively reasonable belief on the part of the person subject to harassing conduct.” rev. denied (Minn. Mar.
- Karla Lynn Mitchell v. Warren Mark Linn Black Minn. Ct. App. 2025
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Karla Lynn Mitchell v. Warren Mark Linn Black
Minn. Ct. App. 2025
–67 (Minn. App. 2006), rev. denied (Minn. Mar.
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Alexander James King v. Rosemary Christine Forschen
Minn. Ct. App. 2025
6 rev. denied (Minn. Mar.
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State of Minnesota v. Soloman Hosea Tomas
Minn. Ct. App. 2025
See id.; (listing 17 requirements for appellant to demonstrate a malicious-prosecution claim), rev. denied (Minn. Mar.
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Presbyterian Family Foundation, On Behalf of Solveig C. Berg v. Robert Neil Norby
Minn. Ct. App. 2025
This definition requires “both objectively unreasonable conduct or intent on the 6 part of the harasser and an objectively reasonable belief on the part of the person subject to harassing conduct.” , rev. denied (Minn. Mar.
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Jamie Marie Kreiner v. Misty Lynn Mahto Monson
Minn. Ct. App. 2025
This definition requires “both objectively unreasonable conduct or intent on the part of the harasser and an objectively reasonable belief on the part of the person being harassed.”
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Kryzta Ellyzabeth-Marie Martinez v. Zhana Jeanette Gunderson
Minn. Ct. App. 2025
4 This definition requires “both objectively unreasonable conduct or intent on the part of the harasser and an objectively reasonable belief on the part of the person subject to harassing conduct.” rev. denied (Minn. Mar.
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Stephen Eric Baldwin v. James D. Connors
Minn. Ct. App. 2025
(noting that the HRO statute requires “objectively unreasonable conduct or intent on the part of the harasser,” and “an objectively reasonable belief on the part of the person subject to harassing conduct”), rev. denied (Minn. Mar.
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Lisa Marie Parkos v. David Andrew Sandbeck
Minn. Ct. App. 2025
A determination of harassment under section 609.748 “requires both objectively unreasonable conduct or intent on the part of the harasser and an objectively reasonable belief on the part of the person subject to the harassing conduct.” rev. denied (Minn. Mar.
- William Jay Tietz v. Janice Mae Tietz Minn. Ct. App. 2025
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In the Matter of: Brooke Lea Simpson v. Miguel Alvarez Soto, Sr.
Minn. Ct. App. 2025
Harassment “requires both objectively unreasonable conduct or intent on the part of the harasser and an objectively reasonable belief on the part of the person subject to harassing conduct.” Dunham v. Roer , rev. denied (Minn. Mar.
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Jessica A Clay v. Roger Day
Minn. Ct. App. 2025
568 (Minn. App. 2006) (noting that a proceeding to obtain an HRO “is civil in nature” and upholding the constitutionality of the HRO statute), rev. denied (Minn. Mar.
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Brooke Lea Simpson and OBO Minor Child v. Joceleyne Maldanado
Minn. Ct. App. 2024
Harassment “requires both objectively unreasonable conduct or intent on the part of the harasser and an objectively reasonable belief on the part of the person subject to harassing conduct.” Dunham v. Roer , , 567 (Minn. App. 2006), rev. 9 denied (Minn. Mar.
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Brooke Lea Simpson and OBO Minor Child v. Arturo Andrade
Minn. Ct. App. 2024
This definition requires “both objectively unreasonable conduct or intent on the part of the harasser and an objectively reasonable belief on the part of the person subject to harassing conduct.” , rev. denied (Minn. Mar.
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Corey Gregory Crowe and OBO Minor Children v. Lila Crowe
Minn. Ct. App. 2024
748 “requires both objectively unreasonable conduct or intent on the part of the harasser and an objectively reasonable belief on the part of the person subject to the harassing conduct.” Dunham v. Roer , rev. denied (Minn. Mar.
- Michelle Lynn Wilson v. Ryan Converse Wilson Minn. Ct. App. 2024
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Michelle Lynn Wilson v. Ryan Converse Wilson
Minn. Ct. App. 2024
The relationship history may provide context for a district court when deciding whether the harasser’s conduct was “objectively unreasonable” and whether the allegations from the person allegedly being harassed constitute an “objectively reasonable belief.” (detailing statutorily required considerations that district courts must use when deciding whether to grant a HRO petition).
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Michael Mansheim OBO Minor Child v. Jenna Kay Westad (A23-1814); Michael Mansheim OBO Minor Child, vs. DeMarco Ramone …
Minn. Ct. App. 2024
Such harassing conduct “requires both objectively unreasonable conduct or intent on the part of the harasser and an objectively reasonable belief on the part of the person subject to harassing conduct.” rev. denied (Minn. Mar.
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In the Matter of: Michael Patrick Rainville v. Michael Anthony Forcia
Minn. Ct. App. 2024
-67 (Minn. App. 2006), rev. denied (Minn. Mar.
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Mikesha Pauline Barnes v. Andrew Christopher Lee
Minn. Ct. App. 2024
1(a)(1) (2022).3 This definition “requires both objectively unreasonable conduct or intent on the part of the harasser and an objectively reasonable belief on the part of the person subject to harassing conduct.” Dunham v. Roer , rev. denied (Minn. Mar.
- In the Matter of: Kaycee Houde v. David Fryxell Minn. Ct. App. 2024
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In the Matter of: Kaycee Houde v. David Fryxell
Minn. Ct. App. 2024
istrict court granted Houde’s civil HRO petition against Fryxell under section 609.748, and this court has held that conduct constituting harassment under section 609.748 does not violate the First Amendment because “the state may regulate certain categories of words or conduct without substantially infringing on speech or expressive conduct protected by the First Amendment.” rev. denied (Minn. Mar.
- Carissa Ann Marsh v. Sean Gregory Samec Minn. Ct. App. 2024
- Allison Marie Wolf v. John Roman Schmainda Minn. Ct. App. 2024
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Allison Marie Wolf v. John Roman Schmainda
Minn. Ct. App. 2024
In order to issue an HRO, a district court must “find that there are reasonable, rather than merely subjective, grounds to believe that the accused engaged in harassment.” rev. denied (Minn. Mar.
- Lindsay Allyn Yates Plumer v. Joseph Mark Plumer, Jr. Minn. Ct. App. 2024
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Lindsay Allyn Yates Plumer v. Joseph Mark Plumer, Jr.
Minn. Ct. App. 2024
“[S]ection 609.748 requires both objectively unreasonable conduct or intent on the part of the harasser and an objectively reasonable belief on the part of the person subject to harassing conduct.” rev. denied (Minn. Mar.
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Kathleen S. Mosdal and OBO Minor children v. Jarred Isaac Mosdal
Minn. Ct. App. 2023
1(a)(1); d 552, 567 (Minn. App. 2006), rev. denied (Minn. Mar.
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Rebecca Lynn Fideldy v. Rose Marie Schumacher
Minn. Ct. App. 2023
Moreover, “the state 9 may regulate certain categories of words or conduct without substantially infringing on speech or expressive conduct protected by the First Amendment.” Dunham v. Roer , ; rev. denied (Minn. Mar.
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Todd Brian Kerber v. Anna Renee McKinnon
Minn. Ct. App. 2023
A harassment determination “requires both objectively unreasonable conduct or intent on the part of the harasser and an objectively reasonable belief on the part of the person subject to harassing conduct.” rev. denied (Minn. Mar.
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Melanie Jane Anderson and obo minor children v. Nicholas Anton Banyai
Minn. Ct. App. 2023
The harassment statute requires the petitioner to establish: (1) “objectively unreasonable conduct or intent on the part of the harasser” and (2) “an objectively reasonable belief on the part of the person subject to harassing conduct .” Peterson, d at 764 (quoting Dunham v. Roer , rev. denied (Minn. Mar.
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Jamie Marie Cambronne, and On Behalf of Minor Children v. Jake Chapp
Minn. Ct. App. 2023
Thus, the HRO statute “requires both objectively unreasonable conduct or intent on the part of the harasser and an objectively reasonable belief on the part of the person subject to harassing conduct.” rev. denied (Minn. Mar.
- Catherine E. Jacobson v. Francesco Parisi Minn. Ct. App. 2023
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Lauren Peterson v. City of Minneapolis, et al
Minn. Ct. App. 2022
Instead, “[t]o present a genuine issue of material fact, affidavits must be based on personal knowledge and set forth facts that would be admissible in evidence.” , rev. denied (Minn. Mar.
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Brita Springstead v. Allen Peterson
Minn. Ct. App. 2022
In Dunham v. Roer, this court observed that a finding of harassment “requires both objectively unreasonable conduct or intent on the part of the harasser and an objectively 6 reasonable belief on the part of the person subject to harassing conduct.” -67 (Minn. App. 2006), rev. denied (Minn. Mar.
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Kari Anne Visser and on behalf of Desirae Mae McPhail and D.J.M., minor child v. Blair E. Willprecht
Minn. Ct. App. 2022
A determination of harassment under section 609.748 “requires both objectively unreasonable conduct or intent on the part of the harasser and an objectively reasonable belief on the part of the person subject to harassing conduct.” Dunham v. Roer, 6 rev. denied (Minn. Mar.
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Heidi Lee Wolf v. Bradley Athmann
Minn. Ct. App. 2022
Thus, a determination of harassment under section 609.748 “requires both objectively unreasonable conduct or intent on the part of the harasser and an objectively reasonable belief on the part of the person subject to harassing conduct.” rev. denied (Minn. Mar.