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

STATE OF MINNESOTA

IN SUPREME COURT

A24-1410

Court of Appeals McKeig, J.

In the Matter of a Public Safety Officer
Death Benefit for Eric William Groebner
(Deceased). Filed: June 3, 2026
Office of Appellate Courts

________________________

Keith Ellison, Attorney General, Cory J. Marsolek, Assistant Attorney General, Saint Paul,
Minnesota, for appellant/cross-respondent Commissioner of Public Safety.

Scott R. Rowland, Joshua Harrison, Meuser, Yackley & Rowland, P.A., Eden Prairie,
Minnesota, for respondent/cross-appellant Holly Groebner.

Daniel R. Kelly, Brandon J. Wheeler, Alec R. Rolain, Felhaber Larson, Minneapolis,
Minnesota for amicus curiae Legal Defense Fund of the Peace Officers Research
Association of California.
________________________

SYLLABUS

1. A public safety officer who dies from a heart attack, stroke, or vascular

rupture is presumed to have been “killed in the line of duty” if the death meets the

presumption criteria under Minn. Stat. § 299A.41, subd. 3(a). For purposes of the

presumption criteria under subdivision 3(a)(1)(i), an emergency response is

presumptively “nonroutine” regardless of how the public safety agency characterizes the

emergency response or whether the emergency response is frequently performed, and the

phrase “nonroutine stressful or strenuous physical” modifies the entire series of items
1
following it: “law enforcement, fire suppression, rescue, hazardous material response,

emergency medical services, prison security, disaster relief, or other emergency response

activity.”

2. If the death does not satisfy the presumption criteria or if the Commissioner

of Public Safety rebuts the presumption with competent medical evidence, the officer’s

estate can present its own medical evidence to show that the officer was “killed in the line

of duty” under Kramer v. State, Peace Officers Ben. Fund, 380 N.W.2d 497 (Minn.

1986), and Johnson v. City of Plainview, 431 N.W.2d 109 (Minn. 1988).

Affirmed in part, reversed in part.

OPINION

MCKEIG, Justice.

In this case, we consider under what circumstances the estate of a public safety

officer who dies from a heart attack, stroke, or vascular rupture is entitled to line-of-duty

death benefits under Minn. Stat. §§ 299A.41–.47 (2022).1 Minnesota Statutes

section 299A.41, subdivision 3(a), states that a public safety officer who died from “a

heart attack, stroke, or vascular rupture … shall be presumed to have died as the direct

and proximate result of a personal injury sustained in the line of duty if” certain criteria

are met. These criteria include circumstances where, in the 24 hours before the heart-

related incident, the officer engaged in a situation or participated in a training exercise

1
Although various amendments to this statutory range have occurred since
Groebner’s death in September 2022, none of them are material to our analysis.

2
involving “nonroutine stressful or strenuous physical” activity. Minn. Stat. § 299A.41,

subd. 3(a)(1)(i)–(ii). While the death benefits statute has existed since the 1970s, the

Legislature added the presumption language for certain heart-related deaths in 2016. Act

of June 1, 2016, ch. 189, art. 14, § 3, 2016 Minn. Laws 885, 1100 (2016 amendments).

Eric William Groebner, a patrol officer with the Anoka Police Department, worked

a 12-hour shift in September 2022. The next day, he died from a vascular rupture. His

widow, Holly Groebner (Ms. Groebner),2 applied for line-of-duty death benefits under

Minn. Stat. §§ 299A.41–.47. The Commissioner of Public Safety (the Commissioner)

denied her application. Ms. Groebner appealed to the then-Office of Administrative

Hearings.3 The Administrative Law Judge (ALJ) granted the Commissioner’s motion for

summary disposition, finding that Groebner did not engage in nonroutine stressful or

strenuous physical law enforcement activity during his last shift and thus, as a matter of

law, his death was not a line-of-duty death under Minn. Stat. § 299A.41, subd. 3. The

court of appeals reversed and remanded, determining that there remained a genuine issue

of material fact as to whether Groebner engaged in nonroutine stressful or strenuous

physical law enforcement or other emergency response activity during his last shift.

2
Throughout the opinion, we refer to the deceased officer as “Groebner” and,
consistent with her brief, refer to his widow as “Ms. Groebner.”
3
The Legislature changed the name of the adjudicating agency from the “Office of
Administrative Hearings” to the “Court of Administrative Hearings” in 2025, after the
Administrative Law Judge’s order granting summary disposition in this case. Act of May
23, 2025, ch. 39, art. 2, § 68, 2025 Minn. Laws 1195, 1245.

3
 The Commissioner petitioned for review as to the meaning of “nonroutine” under

Minn. Stat. § 299A.41, subd. 3(a)(1)(i). Ms. Groebner conditionally cross-petitioned for

review of whether, even if the presumption criteria are not met, the definition of “killed in

the line of duty” that we articulated in Kramer v. State, Peace Officers Ben. Fund, 380

N.W.2d 497 (Minn. 1986), and Johnson v. City of Plainview, 431 N.W.2d 109 (Minn.

1988), remains good law after the Legislature added the presumption language in its 2016

amendments. We granted both petitions.

For reasons discussed below, we determine that “nonroutine” under Minn. Stat.

§ 299A.41, subd. 3(a)(1)(i), is ambiguous and, based upon the legislative history, we

construe the term to have a meaning consistent with the federal death benefits statute.

Accordingly, we hold that an emergency response is presumptively “nonroutine” under

Minn. Stat. § 299A.41, subd. 3(a)(1)(i), regardless of how the public safety agency

characterizes the emergency response or whether the emergency response is frequently

performed. We also hold that the statutory phrase “nonroutine stressful or strenuous

physical” modifies the entire series of items following it in Minn. Stat. § 299A.41, subd.

3(a)(1)(i), not just “law enforcement,” such that any activity that satisfies the presumption

must be “nonroutine stressful or strenuous physical.” Applying this construction, we

affirm on different grounds the court of appeals holding that there is a genuine issue of

material fact as to whether Groebner engaged in nonroutine stressful or strenuous

physical law enforcement or other emergency response activity during his last shift.

We also hold that the presumption of compensability for deaths from heart attack,

stroke, or vascular rupture under the 2016 amendments did not replace the Kramer and

4
Johnson definition of “killed in the line of duty” for those deaths; if the death does not

satisfy the presumption criteria or the Commissioner rebuts the presumption with

competent medical evidence, the officer’s estate can present its own medical evidence to

show that the officer was “killed in the line of duty” under Kramer and Johnson. We

reverse the court of appeals holding to the contrary.

FACTS

Groebner served as a patrol officer for the City of Anoka Police Department from

February 2014 until his death in September 2022. On September 13, 2022, Groebner

worked from 10:00 a.m. to 10:00 p.m. and responded to 11 calls. Based on the Anoka

Police Department incident data, call summaries, and dash and body camera footage, we

summarize the calls that Groebner responded to as follows:

1. 10:07–10:25 a.m. Burglary. Groebner assisted a Ramsey Police Department
search for a burglary suspect. Other officers arrested the suspect later that
afternoon.
2. 10:25–10:27 a.m. Suspicious person. Groebner responded to a call reporting
that a person was possibly burning something in a gas station bathroom. The
person left the gas station before officers arrived.
3. 11:33 a.m.–12:06 p.m. Warrant. Groebner ran a driver’s license inquiry for a
warrant investigation.
4. 12:17–12:22 p.m. Traffic stop. Groebner pulled over a driver for a
malfunctioning brake light and turn signal. He did not issue a ticket.
5. 2:18–2:33 p.m. Trespassing. Groebner responded to a call reporting that a man
was trespassing and may attempt to break into a house. Groebner issued a
warning.
6. 3:54–4:16 p.m. Traffic stop. Groebner pulled a driver over for speeding in a
school zone.4

4
The Anoka Police Department’s summary of Groebner’s activities on September
13, 2022, states that Groebner issued a speeding ticket, but the body camera footage
shows that Groebner issued a warning, not a ticket.

5
 7. 4:18–4:20 p.m. Suspicious person. Groebner and other officers were
dispatched to a location where people were working on a car in the driveway of
a home while the homeowners were out of town. When officers arrived, no one
was there, and the residence was secure.
8. 4:20–4:26 p.m. Domestic. Groebner responded to a phone report of a possible
domestic dispute. The department called the reporting number, left a voicemail,
and received no response.
9. 5:34–6:00 p.m. Domestic. Groebner and another officer responded to a call
reporting a child with a knife. Groebner drove to the scene through a residential
neighborhood, reaching a top speed of 59 miles per hour. There was no evidence
of a knife when Groebner arrived. Groebner spoke separately with the father and
the son outside the residence. The son said his mother yelled at him for chasing
his sister; the father said the son was not listening to him and was causing a
scene. Groebner mediated the situation and both parties went back inside.
10. 6:03–6:09 p.m. Theft report. Groebner was dispatched to a theft report, but the
department was unable to reach the reporting party.
11. 6:54–7:00 p.m. Follow up. Groebner tried to follow up with the reporting party.

Groebner returned home around 10:00 p.m. He woke up the next morning and put

his two children on the bus around 8:45 a.m. He did not say anything to Ms. Groebner

that morning about not feeling well. Ms. Groebner returned from work later that day and

found Groebner on the floor of the basement bathroom. The medical examiner

determined that the cause of Groebner’s death was a “rupture of ascending aortic

aneurysm with cardiac tamponade,” and the manner of death was “natural.”5

Ms. Groebner began receiving benefits from the Minnesota Public Employees

Retirement Association in December 2022. She applied to the federal Public Safety

Officers’ Benefits Office for benefits under 34 U.S.C. § 10281, and she also applied to

5
The parties agree that this rupture was a “vascular rupture.” The ALJ and court of
appeals also refer to this rupture as a “vascular rupture.” In re Groebner, No. A24-1410,
2025 WL 1430594, at *1 (Minn. App. May 19, 2025). Thus, there is no dispute that
Groebner died from a vascular rupture under Minn. Stat. § 299A.41, subd. 3(a).

6
the Commissioner for state benefits under Minn. Stat. §§ 299A.41–.47. Along with her

application to the Minnesota Department of Public Safety, Ms. Groebner submitted,

among other things, the autopsy report, the death certificate, Ms. Groebner’s timeline of

the 24 hours before finding Groebner, and a medical expert’s report. In the report, the

medical expert opined that “the intensely stressful nature of police work contributed to

the development and aggravation of [Groebner’s] anxiety and hypertension, both of

which are causally related to the initiation and progression of aortic and cardiovascular

disease.” The expert did not address whether the specific activities Groebner engaged in

during his last shift contributed to the vascular rupture.

Ms. Groebner’s application for federal death benefits was approved but her

application for Minnesota death benefits was not. In October 2023, the federal Public

Safety Officers’ Benefits Office determined that Groebner’s death was covered by 34

U.S.C. § 10281 because Groebner “died as the direct and proximate result of a heart

attack suffered not later than 24 hours after engaging in an on-duty situation involving

nonroutine stressful physical emergency response activity.” The following month, the

Commissioner notified Ms. Groebner that Groebner was “not eligible for the Line of

Duty Death Benefit” because he “did not die in the line of duty as a peace officer at the

time of his death, as defined by Minn. Stat. § 299A.41, subd. 3.”

Ms. Groebner appealed the Commissioner’s decision to the Office of

Administrative Hearings. The Commissioner moved for summary disposition, submitting

exhibits including Anoka Police Department documents and body and dash camera video

related to Groebner’s last patrol shift. Along with her motion against summary

7
disposition, Ms. Groebner included a June 19, 2024 affidavit from Drew Moldenhauer, a

Minnesota police officer with 17 years of experience. In his affidavit, Moldenhauer stated

that the domestic disturbance call that Groebner responded to during his last shift

“involved … nonroutine stressful or strenuous physical law enforcement or other

emergency response activity.”

The ALJ granted summary disposition.6 The ALJ found that there was no genuine

dispute of material fact and that Groebner’s last shift did not consist of “nonroutine

stressful or strenuous law enforcement activity” as a matter of law because, under our

decisions in Kramer and Johnson, Groebner’s performance of his duties did not “expose

[him] to the hazard of being killed.” See Kramer, 380 N.W.2d at 501 (defining “killed in

the line of duty” as “death resulting from the performance of those duties peculiar to a

peace officer that expose the officer to the hazard of being killed”); Johnson, 431 N.W.2d

at 115 (defining “killed in the line of duty” as “any death which results in part from the

performance of” “hazardous work in protection of the public”).

Ms. Groebner appealed the ALJ’s decision, and the court of appeals reversed and

remanded. In re Groebner, No. A24-1410, 2025 WL 1430594 (Minn. App. May 19,

2025). The court of appeals held that the Kramer and Johnson definition of “killed in the

line of duty” did not apply because those cases do not control “deaths specifically

6
The ALJ first issued an order recommending that the Department of Public Safety
grant summary disposition. The next day, the Office of Administrative Hearings issued a
correction that the order “serve[d] as the binding and final decision in this matter” under
Minn. Stat. § 299A.43.

8
included or excluded by the [L]egislature in Minn. Stat. § 299A.41, subd. 3,” including

deaths from vascular ruptures. Id. at *3 n.4 (citation omitted) (internal quotation marks

omitted). The court also held that “nonroutine” means “not customary, mechanically

performed, or part of the regular course of procedure.” Id. at *5. Applying this

interpretation, the court of appeals concluded that there remained a genuine issue of

material fact as to whether the domestic disturbance call was nonroutine and stressful and

held that the ALJ erred by granting summary disposition. Id. at *5–7.

One court of appeals judge dissented, concluding that “nonroutine” means “special

or extraordinary.” Id. at *9 (Johnson, J., dissenting). Applying this definition, the

dissenting judge would have affirmed the ALJ, holding that there was no genuine issue of

material fact as to whether Groebner’s activity during his last shift was “nonroutine”

under Minn. Stat. § 299A.41, subd. 3. Id. at *11.

ANALYSIS

The State of Minnesota provides a one-time death benefit to eligible family

members or to the estate of a public safety officer who is killed in the line of duty. Minn.

Stat. § 299A.44, subds. 1(a), 2 (providing $100,000 in benefits, adjusted over time based

on changes to the Consumer Price Index). Minnesota Statutes section 299A.41,

subdivision 3, of the public safety officer death benefits statute defines the phrase “killed

in the line of duty.” This provision excludes “deaths from natural causes” from line-of-

duty deaths. Id. Before the 2016 amendments, subdivision 3 did not expressly address

whether an officer who suffered a heart-related death could be considered “killed in the

line of duty.” Minn. Stat. § 299A.41, subd. 3 (2014). In the absence of statutory guidance,

9
we considered whether officers who suffered heart-related deaths were killed in the line

of duty in two cases: Kramer, 380 N.W.2d 497, and Johnson, 431 N.W.2d 109. In those

cases, we defined “killed in the line of duty” as “any death which results in part” “from

the performance of those duties peculiar to a peace officer that expose the officer to the

hazard of being killed.” Johnson, 431 N.W.2d at 114–15 (quoting Kramer, 380 N.W.2d at

501) (internal quotation marks omitted).

In its 2016 amendments, the Legislature amended section 299A.41 to add a

presumption that certain heart-related deaths are in the line of duty. Today, Minn. Stat.

§ 299A.41, subd. 3, defines “killed in the line of duty” in pertinent part as follows, with

the language added and removed by the 2016 amendments demarcated:

(a) “Killed in the line of duty” does not include deaths from natural causes,
except as provided in this subdivision. In the case of a peace public safety
officer, “killed in the line of duty” includes the death of an a public safety
officer caused by accidental means while the peace public safety officer is
acting in the course and scope of duties as a peace public safety officer. Killed
in the line of duty also means if a public safety officer dies as the direct and
proximate result of a heart attack, stroke, or vascular rupture, that officer
shall be presumed to have died as the direct and proximate result of a personal
injury sustained in the line of duty if:
(1) that officer, while on duty:
(i) engaged in a situation, and that engagement involved nonroutine
stressful or strenuous physical law enforcement, fire suppression,
rescue, hazardous material response, emergency medical services,
prison security, disaster relief, or other emergency response activity;
or
(ii) participated in a training exercise, and that participation involved
nonroutine stressful or strenuous physical activity;
(2) that officer died as a result of a heart attack, stroke, or vascular rupture
suffered: …
(iii) not later than 24 hours after engaging or participating under
clause (1); and
(3) the presumption is not overcome by competent medical evidence to the
contrary.

10
Minn. Stat. § 299A.41, subd. 3(a); 2016 amendments.

The dispute in this case centers on whether Groebner was killed in the line of duty.

The answer to that question requires us to interpret section 299A.41, subdivision 3(a). We

first must determine the meaning of the statutory criteria that give rise to the presumption

that the officer died as the direct and proximate result of a personal injury. In particular,

we assess whether Groebner’s death was “nonroutine” as that term is used in the statutory

definition of “killed in the line of duty,” and whether the phrase “nonroutine stressful or

strenuous physical” modifies only “law enforcement” or the entire series of nouns that

follow it in subdivision 3(a)(1)(i). Next, we address whether the 2016 amendments’

presumption of compensability for certain heart-related deaths replaced the Kramer and

Johnson definition of “killed in the line of duty” for those types of deaths or whether, in

circumstances where the presumption does not apply or is rebutted, the standard from

those decisions continues to apply. Statutory interpretation is a legal question that we

review de novo. Pietsch v. Minn. Bd. of Chiropractic Exam’rs, 683 N.W.2d 303, 306

(Minn. 2004).

I.

The statutory presumption in Minn. Stat. § 299A.41, subd. 3, that the “officer shall

be presumed to have died as the direct and proximate result of a personal injury sustained

in the line of duty,” applies if certain criteria are met. At issue here is the requirement in

subdivision 3(a)(1)(i) that the officer, while on duty, “engaged in a situation, and that

engagement involved nonroutine stressful or strenuous physical law enforcement, fire

suppression, rescue, hazardous material response, emergency medical services, prison

11
security, disaster relief, or other emergency response activity.” The parties dispute the

meaning of the term “nonroutine” as well as the scope of what the phrase “nonroutine

stressful or strenuous physical” modifies.

A.

First, we interpret the meaning of “nonroutine” in Minn. Stat. § 299A.41, subd.

3(a)(1)(i). We interpret statutes to “ascertain and effectuate the intention of the

[L]egislature.” Minn. Stat. § 645.16. “The plain language of the statute is our best guide

to the Legislature’s intent” and, “[i]f the statutory language is clear,” we apply the plain

meaning of the statute. Rodriguez v. State Farm Mut. Auto. Ins. Co., 931 N.W.2d 632,

634 (Minn. 2019). If the statute “is reasonably susceptible to more than one

interpretation” it is ambiguous, and we apply canons of construction to determine

legislative intent. In re Welfare of J.B., 782 N.W.2d 535, 539–40 (Minn. 2010) (citation

omitted) (internal quotation marks omitted).

Ms. Groebner argues that “nonroutine” under Minn. Stat. § 299A.41, subd.

3(a)(1)(i), plainly means “not customary, mechanically performed, or part of an officer’s

regular course of procedure,” as held by the court of appeals. Groebner, 2025 WL

1430594, at *5. The Commissioner argues that “nonroutine” means “special or

extraordinary,” as concluded by the court of appeals dissent. Id. at *9 (Johnson, J.,

dissenting). First, we consider whether the term “nonroutine” under Minn. Stat.

§ 299A.41, subd. 3(a)(1)(i), has a plain meaning or is ambiguous.

12
 1.

To determine whether “nonroutine” is ambiguous, we look to its common,

ordinary meaning. See Getz v. Peace, 934 N.W.2d 347, 354 (Minn. 2019); Minn. Stat.

§ 645.08(1). “[W]hen the Legislature has not provided definitions of the relevant term …

we may consider dictionary definitions to determine a word’s common usage.” Getz, 934

N.W.2d at 354. The parties have not cited, and we have not identified, any physical

dictionaries that define “nonroutine.” The American Heritage Dictionary defines “non” as

“[n]ot” and lists definitions for “routine” as both a noun and an adjective. 1198, 1529–30

(5th ed. 2018). Because “nonroutine” operates as an adjective in the statute, we consider

definitions of “routine” as an adjective. They are: “1. In accord with established

procedure: a routine check of passports. 2. Habitual; regular: made his routine trip to the

store. 3. Having no special quality; ordinary: a routine day.” Id. at 1529–30.

These dictionary definitions provide some support for both parties’ interpretations

of “nonroutine.” The first and second dictionary definitions of “routine”—“[i]n accord

with established procedure,” “[h]abitual,” and “regular”—support part of Ms. Groebner’s

interpretation that “nonroutine” means “not customary … or part of the regular course of

procedure.”7 The second and third definitions of “routine” as “regular” and “[h]aving no

7
We note, however, that none of The American Heritage Dictionary definitions of
“routine” as an adjective support the part of Ms. Groebner’s interpretation that
“nonroutine” means not “mechanically performed”—this derives from a dictionary
definition of “routine” as a noun, which is inapplicable here. 1529 (5th ed. 2018) (“1a. A
set of customary or unchanging and often mechanically performed activities or
procedures: a routine of housework.”).

13
special quality; ordinary” support the Commissioner’s interpretation that “nonroutine”

means “special or extraordinary.”8

Because the meaning of “nonroutine,” as used in Minn. Stat. § 299A.41, subd.

3(a)(1)(i), is “reasonably susceptible to more than one interpretation,” it is ambiguous.9

See Welfare of J.B., 782 N.W.2d at 540.

2.

When a statute is ambiguous, we may consider canons of construction to ascertain

the Legislature’s intent, including the circumstances under which the statute was enacted

and the statute’s “contemporaneous legislative history.” Scheurer v. Shrewsbury, 24

N.W.3d 670, 678 (Minn. 2025); Minn. Stat. § 645.16(2), (7). We have also generally held

that “[w]here the state statute is the same or substantially the same as the federal act from

which it was copied, the prior construction of the federal statute should be deemed

controlling by us in construing the state statute.” State v. Stickney, 5 N.W.2d 351, 352

(Minn. 1942); Minn. Citizens Concerned for Life, Inc. v. Kelley, 698 N.W.2d 424, 429

(Minn. 2005).

8
The online dictionary definitions of “nonroutine” noted by the court of appeals
likewise provide some support for both parties’ interpretations. The online Merriam-
Webster Dictionary was cited as defining “nonroutine” as including “not of a
commonplace or repetitious character,” which supports Ms. Groebner’s interpretation,
while the online Cambridge Dictionary defined “non-routine” as “special or unusual,
rather than part of what usually happens,” which supports the Commissioner’s
interpretation. See Groebner, 2025 WL 1430594, at *5 n.5.
9
While we can sometimes discern from statutory context which of multiple possible
dictionary definitions apply, that is not the case here. Cf. State v. Johnson, 995 N.W.2d
155, 160–61 (Minn. 2023).
14
 In 2016, the federal death benefits statute contained the following presumption

that certain heart-related deaths are line-of-duty deaths:

(k) Death by heart attack, stroke, or vascular rupture; presumption
As determined by the bureau, a heart attack, stroke, or vascular rupture
suffered by a public safety officer shall be presumed to constitute a personal
injury … sustained in the line of duty by the officer and directly and
proximately resulting in death, if--
(1) the public safety officer, while on duty--
(A) engages in a situation involving nonroutine stressful or strenuous
physical law enforcement, fire suppression, rescue, hazardous
material response, emergency medical services, prison security,
disaster relief, or other emergency response activity; or
(B) participates in a training exercise involving nonroutine stressful
or strenuous physical activity;
(2) the heart attack, stroke, or vascular rupture commences ….
(C) not later than 24 hours after the officer is engaged or participating
as described in paragraph (1); and
(3) the heart attack, stroke, or vascular rupture directly and proximately
results in the death of the public safety officer, unless competent medical
evidence establishes that the heart attack, stroke, or vascular rupture was
unrelated to the engagement or participation or was directly and proximately
caused by something other than the mere presence of cardiovascular-disease
risk factors.

(l) Definition
For purposes of subsection (k) of this section, “nonroutine stressful or
strenuous physical” excludes actions of a clerical, administrative, or
nonmanual nature.

42 U.S.C. § 3796(k)–(l) (2016) (transferred to 34 U.S.C. § 10281 as of September 2017).

These provisions of the federal death benefits statute have remained substantially the

same since 2016. See 34 U.S.C. § 10281(k)–(l). Minnesota Statutes section 299A.41,

subdivision 3(a)(1), is substantially similar—indeed, at points identical—to this federal

statute. The close overlap in language and purpose is a strong signal that the Minnesota

Legislature intended the Minnesota Statutes to reflect the federal law.

15
 The legislative history of Minn. Stat. § 299A.41, subd. 3, confirms that the

Legislature intended the 2016 amendments to bring the Minnesota death benefits statute

into “conformity” with the heart-related deaths presumption in the federal public safety

officers’ benefits statute, 42 U.S.C. § 3796(k) (2016). Hearing on H.F. 2810, H. Comm.

Pub. Safety & Crime Prevention Pol’y & Fin., 89th Minn. Leg., Mar. 22, 2016 (video

tape) (statement of Jeff Howe). The goal of the 2016 amendments, as articulated by the

bill’s sponsor, Representative Howe, was to give grieving families a “one-stop shop” at

the Department of Public Safety, such that the Commissioner’s determination that the

officer was “killed in the line of duty” would satisfy both the state and federal death

benefits statutes. Id. As sponsor, Representative Howe’s description of the bill’s purpose

or effect “is entitled to some weight in construing the statute.” See Scheurer, 24 N.W.3d

at 678 (citation modified). His statements are also corroborated by the house summary of

the bill: “This bill conforms Minnesota’s definition of ‘killed in the line of duty’ with the

definition found in the federal Hometown Heroes Act for purposes of awarding benefits

to the survivors of public safety officers who are killed in the line of duty.”10 H. Res. Bill

Summary: H.F. 2810 (Mar. 22, 2016). Because the Legislature enacted statutory text very

similar to the existing federal death benefits statute and the purpose of the 2016

amendments was to align the state and federal public safety benefit schemes, we look to

the federal death benefits statute, its implementing regulations, and relevant agency

10
“Hometown Heroes Act” is the name of the legislation amending the federal death
benefits statute to include the heart-related deaths presumption. Hometown Heroes
Survivors Benefits Act of 2003, Pub. L. No. 108–182, 117 Stat. 2649 (2003).

16
memoranda for insight into the meaning of “nonroutine” under Minn. Stat. § 299A.41,

subd. 3(a)(1)(i). See Stickney, 5 N.W.2d at 352; Great N. Invs., Inc. v. Comm’r of Tax’n,

127 N.W.2d 444, 449 (Minn. 1964); Shrewsbury, 24 N.W.3d at 678.

While the federal statute does not define “nonroutine” and only defines

“nonroutine stressful or strenuous physical” insofar as it “excludes actions of a clerical,

administrative, or nonmanual nature,” the statute’s implementing regulations, also in

effect in 2016, do offer definitions:

Nonroutine stressful or strenuous physical activity means nonroutine
stressful physical activity or nonroutine strenuous physical activity.

Nonroutine strenuous physical activity means line of duty activity that—
(1) Is not excluded by the Act, at 34 U.S.C. 10281(l);
(2) Is not performed as a matter of routine; and
(3) Entails an unusually-high level of physical exertion.

Nonroutine stressful physical activity means line of duty activity that—
(1) Is not excluded by the Act, at 34 U.S.C. 10281(l);
(2) Is not performed as a matter of routine;
(3) Entails non-negligible physical exertion; and
(4) Occurs—
(i) With respect to a situation in which a public safety officer
is engaged, under circumstances that objectively and
reasonably—
(A) Pose (or appear to pose) significant dangers, threats,
or hazards (or reasonably-foreseeable risks thereof), not
faced by similarly-situated members of the public in the
ordinary course; and
(B) Provoke, cause, or occasion an unusually-high level
of alarm, fear, or anxiety; or
(ii) With respect to a training exercise in which a public
safety officer participates, under circumstances that
objectively and reasonably—
(A) Simulate in realistic fashion situations that
pose significant dangers, threats, or hazards; and
(B) Provoke, cause, or occasion an unusually-
high level of alarm, fear, or anxiety.

17
 Routine—Neither of the following shall be dispositive in determining
whether an activity or action shall be understood to have been performed as
a matter of routine:
(1) Being generally described by the public safety agency as routine
or ordinary; or
(2) The frequency with which it may be performed.11

28 C.F.R. § 32.13. These definitions apply to “nonroutine stressful or strenuous physical”

under 34 U.S.C. § 10281(k)(1)(A)–(B).

While the federal regulations do not expressly define “nonroutine,” the definitions

of both “[n]onroutine strenuous physical activity” and “[n]onroutine stressful physical

activity” reflect that under federal law, nonroutine means “not performed as a matter of

routine.” Second, the definition of “[r]outine” tells us what the Bureau of Justice

Assistance (BJA)—which plays a similar role to the Commissioner in awarding line-of-

duty death benefits—may not consider dispositive when determining whether an activity

is nonroutine: the relevant public safety agency’s description of the activity or the

frequency with which the activity may be performed.

An October 2007 BJA memorandum also addresses the subject.12 See In re

Issuance of Air Emissions Permit No. 13700345-101 for PolyMet Mining, Inc., City of

11
In 2016, before the federal death benefits statute was transferred to 34 U.S.C.
§ 10281, the definitions of “[n]onroutine strenuous physical activity” and “[n]onroutine
stressful physical activity” referred to 42 U.S.C. § 3796(l). 28 C.F.R. § 32.13 (2016).
12
We also reviewed the two federal appellate cases providing illustrative examples
of “nonroutine” under 34 U.S.C. § 10281. In Watkins v. Department of Justices, a public
safety officer passed out while on break “from performing traffic and crowd control at
graduation ceremonies” and remained unconscious until he died two weeks later. 809
Fed. Appx. 923, 924 (Fed. Cir. 2020). The Federal Circuit affirmed the finding of the BJA
that performance of “traffic and crowd control at graduation ceremonies” amounted to
“routine patrol activities” and “did not involve nonroutine or strenuous physical law
18
Hoyt Lakes, St. Louis Cnty., Minn., 955 N.W.2d 258, 266 (Minn. 2021) (observing that a

federal agency’s informal interpretation of a federal statute may be given persuasive

weight). In October 2007, the BJA issued a memorandum establishing a “policy and

practice of the Public Safety Officers’ Benefits Program” when determining whether an

activity is “nonroutine stressful or strenuous physical.” Memorandum from the Office of

the Director for the Bureau of Justice Assistance on Public Safety Officers’ Benefits

Program Policy Memorandum re: “Nonroutine stressful or strenuous physical activity”

(Oct. 2, 2007) (October 2007 Memo). The memo provided that no activity should be

considered routine based only on the public safety agency’s description of the activity. Id.

The memo also stated that whether an activity is nonroutine “should be informed less by

the frequency with which it may be performed than by its stressful or strenuous

character.” Id. These concepts were later incorporated into the regulations’ definition of

“routine,” added after the October 2007 Memo. 28 C.F.R. § 32.13; see 28 C.F.R. § 32.13

(2006) (defining “[n]onroutine strenuous physical activity,” “[n]onroutine stressful or

enforcement activity” under 34 U.S.C. § 10281(k) “and its implementing regulations.”
Watkins, 809 Fed. Appx. at 924–26.
In Afolayan v. Department of Justice, a public safety officer completed a training
run in 88-degree weather at 3,400 feet above sea level, collapsed, and died a day later.
No. 2021-1452, 2022 WL 1124965, at *1 (Fed. Cir. Apr. 15, 2022). In its discussion of
evaluating “cognizable ‘injury,’ ” the Federal Circuit noted that the heart-related deaths
presumption “explicitly excluded situations involving routine activities, even if they were
stressful or strenuous; ‘nonroutine’ activity was required.” Id. at *2–4. The court
continued that “[t]he regulation [28 C.F.R. § 32.3], read in light of its history and the
statute as a whole, requires a finding of nonroutine or out-of-the-ordinary climatic
conditions for compensation.” Id. at *4.
19
strenuous physical activity,” and “[n]onroutine stressful physical activity,” but not

“routine”).

The memo further explains that domestic disturbance calls, traffic stops, and fire

alarms, though frequently occurring, usually “occasion considerable stress” in part

because they involve many “serious unknowns.” October 2007 Memo. The memo

concludes: “Responding to an emergency call shall presumptively be treated as non-

routine.” Id. In a senate hearing two days after the memo’s publication, the BJA Director

characterized the memo as “provid[ing] binding direction so that no activity will be

considered routine simply because the officer might engage in it regularly” and “that

emergency calls will be considered non-routine.” Justice Denied: Implementation of the

Hometown Heroes Survivors Benefits Act: Hearing Before the S. Comm. on the Judiciary,

110th Cong. 13 (2007) (statement of Domingo S. Herraiz, Director, BJA, Office of

Justice Program, Department of Justice).13

We find the federal statute, its corresponding regulations, and the October 2007

Memo informative and persuasive as to the interpretation of “nonroutine” in Minn. Stat.

§ 299A.41, subd. 3(a)(1)(i). The Minnesota Legislature intended to conform the state

death benefits statute with its federal counterpart. The federal statute, as well as its

corresponding regulations, are substantively the same now as they were when the

13
At this hearing, the committee expressed concern that the BJA was not granting
benefits to deserving survivors and taking too long to process survivors’ benefits claims,
and the BJA Director presented the October 2007 Memo as reducing ambiguity of the
term “nonroutine” to help solve these problems. Justice Denied, 110th Cong. 1–13.

20
Minnesota Legislature added the statutory presumption to Minn. Stat. § 299A.41 in 2016.

And the October 2007 Memo—whose concepts were incorporated into the regulations—

controls how the BJA determines whether an officer engaged in “nonroutine stressful or

strenuous physical” activity.

Having considered the text of Minn. Stat. § 299A.41, subd. 3(a)(1)(i), and the

federal authorities with which the Minnesota Legislature intended to bring the statute in

conformity, we hold that an emergency response is presumptively “nonroutine” under the

statute, regardless of how the public safety agency characterizes the emergency response

or whether the emergency response is frequently performed. We further observe that,

consistent the Minnesota Legislature’s intent for conformity with federal law, these same

authorities likewise inform the presumption’s “nonroutine stressful or strenuous physical”

requirement in Minn. Stat. § 299A.41, subd. 3(a)(1)(i).14 However, we caution that a

determination of federal benefits in any particular case does not bind the Commissioner’s

determination of state benefits in that case.

14
We need not decide here the weight the federal authorities are to be given if the
federal statute or regulations had been substantively amended since the Minnesota
Legislature’s inclusion of the statutory presumption, nor the federal authorities’ weight if
the Commissioner promulgated its own rules on the issue. Here, the federal statute and
corresponding federal regulations have not been substantively amended since the
Minnesota Legislature added the statutory presumption in 2016. Nor has the
Commissioner exercised his authority to “adopt rules under chapter 14 to implement,
coordinate, and administer section[] 299A.41 ….” Minn. Stat. § 299A.46.

21
 B.

We next consider whether the phrase “nonroutine stressful or strenuous physical”

in Minn. Stat. § 299A.41, subd. 3(a)(1)(i), modifies only “law enforcement” or the entire

series that follows it: “law enforcement, fire suppression, rescue, hazardous material

response, emergency medical services, prison security, disaster relief, or other emergency

response activity.” Ms. Groebner argues that the phrase modifies only “law enforcement”

such that, so long as Groebner engaged in “emergency response activity” during his last

shift, his death fulfills the presumption regardless of whether that activity was

“nonroutine stressful or strenuous physical.” The Commissioner argues that the phrase

modifies the entire series of nouns that follows it, such that any activity that satisfies the

presumption must be “nonroutine stressful or strenuous physical.”

We interpret statutory “words and phrases … according to rules of grammar and

according to their most natural and obvious usage unless it would be inconsistent with the

manifest intent of the legislature.” ILHC of Eagan, LLC v. County of Dakota, 693 N.W.2d

412, 419 (Minn. 2005); Minn. Stat. § 645.08(1). The “series qualifier rule of grammar …

states that ‘[w]hen there is a straightforward, parallel construction that involves all nouns

or verbs in a series, a … [qualifier] normally applies to the entire series.’ ” State v. Khalil,

956 N.W.2d 627, 634 (Minn. 2021) (quoting Antonin Scalia & Bryan A. Garner, Reading

Law: The Interpretation of Legal Texts 147 (2012)); see also State v. Stay, 935 N.W.2d

428, 432 (Minn. 2019).

We apply the series qualifier rule when “[t]he sentence is structured as an easily

digestible series of similar nouns,” and the qualifier sensibly and easily applies to each

22
noun. Khalil, 956 N.W.2d at 634–35 (holding the series qualifier rule applied and that

“administered to that person without the person’s agreement” modified every noun in

“alcohol, a narcotic, anesthetic, or any other substance”); Stay, 935 N.W.2d at 432

(holding the series qualifier rule did not apply because the allegedly-modified clauses

were “not parallel” and did “not form an easy, digestible list”). Here, Minn. Stat.

§ 299A.41, subd. 3(a)(1)(i), contains a very simple and straightforward, easily digestible

list of parallel and similar nouns: “law enforcement, fire suppression, rescue, hazardous

material response, emergency medical services, prison security, disaster relief, or other

emergency response activity.” See Khalil, 956 N.W.2d at 634. The phrase “nonroutine

stressful or strenuous physical” sensibly applies to each item listed. Id. Thus, the series

qualifier rule applies to Minn. Stat. § 299A.41, subd. 3(a)(1)(i).15

15
Rather than argue against applying the series qualifier grammar rule,
Ms. Groebner argues that other provisions in the statute support her position. We “read a
particular provision in context with other provisions of the same statute in order to
determine the meaning of the particular provision.” State v. Riggs, 865 N.W.2d 679, 683
(Minn. 2015). Ms. Groebner argues that, had the Legislature intended for “nonroutine
stressful or strenuous physical” to modify every noun in the series, it would have put a
colon after the modifying phrase as it did in subdivision 3(a)(2).
The Commissioner counters by comparing subdivision 3(a)(1)(i) with subdivision
3(a)(1)(ii). See Minn. Stat. § 299A.41, subd. 3(a)(1)(ii) (stating an officer can qualify for
the heart-related deaths presumption by “participat[ing] in a training exercise, [where]
that participation involved nonroutine stressful or strenuous physical activity”). Any
qualifying training exercise, which could involve any of the activities listed in
subdivision 3(a)(1)(i), must involve “nonroutine stressful or strenuous physical activity.”
The Commissioner argues it logically follows that “nonroutine stressful or strenuous
physical” also modifies all activities listed in subdivision 3(a)(2)(i). We find the
Commissioner’s argument persuasive. The context of the statute shows that the
Legislature intended for an officer’s heart-related death to meet the presumption if they
engaged in “nonroutine stressful or strenuous physical” activity, whether it was an
activity listed in subdivision 3(a)(1)(i) or a training exercise in subdivision 3(a)(1)(ii).
23
 We hold that “nonroutine stressful or strenuous physical” in Minn. Stat.

§ 299A.41, subd. 3(a)(1)(i), unambiguously modifies the entire series of activities that

follow it. Accordingly, any activity that satisfies the presumption under Minn. Stat.

§ 299A.41, subd. 3(a)(1)(i), must be “nonroutine stressful or strenuous physical.”

C.

Now that we have construed “nonroutine” and “nonroutine stressful or strenuous

physical,” we next determine whether, as a matter of law, Groebner’s death was not

entitled to the presumption that he was “killed in the line of duty” under Minn. Stat.

§ 299A.41, subd. 3. “Summary disposition is the administrative equivalent of summary

judgment.” Pietsch, 683 N.W.2d at 306. Like summary judgment, we review summary

disposition to determine whether there are any genuine issues of material fact and

whether there was an error in applying the law to the facts. Id. In doing so, we consider

the evidence in the “light most favorable to the nonmoving party.” Henson v. Uptown

Drink, LLC, 922 N.W.2d 185, 190 (Minn. 2019) (citation omitted) (internal quotation

marks omitted).

The parties dispute whether Groebner’s death was entitled to the presumption that

he was “killed in the line of duty” under Minn. Stat. § 299A.41, subd. 3, as a matter of

law, each using their preferred definition of “nonroutine.” The Commissioner argues that

Groebner’s death did not meet the presumption criteria as a matter of law and asks us to

reverse the court of appeals and reinstate the ALJ’s summary disposition order.

Ms. Groebner contends that Groebner’s death met the presumption criteria or,

alternatively, that there is a genuine issue of material fact as to whether he met the

24
criteria, and that we should affirm the court of appeals. The parties agree that Groebner

died from a vascular rupture within 24 hours of his final shift, and they seem to agree that

Groebner’s activities during his shift were not “strenuous.” They dispute whether his shift

involved nonroutine stressful physical law enforcement or other emergency response

activity under Minn. Stat. § 299A.41, subd. 3(a)(1)(i).

For Groebner’s death to meet the presumption criteria under Minn. Stat.

§ 299A.41, subd. 3, Ms. Groebner must show that, during Groebner’s shift on September

13, 2022, he engaged in a situation involving nonroutine stressful or strenuous physical

law enforcement or other emergency response activity. Ms. Groebner can show that

Groebner presumptively engaged in “nonroutine” activity by showing that he responded

to an emergency call. She must also show that the activity was “stressful physical”

activity, which, as informed by corresponding federal authorities, may be met if the

activity “entail[ed] non-negligible physical exertion”; occurred “under circumstances that

objectively and reasonably … [p]ose (or appear to pose) significant dangers, threats, or

hazards (or reasonably-foreseeable risks thereof), not faced by similarly-situated

members of the public in the ordinary course”; and “provoke[d], cause[d], or

occasion[ed] an unusually-high level of alarm, fear, or anxiety.” See 28 C.F.R. § 32.13.

Reviewing the facts in the light most favorable to Ms. Groebner, we hold that there

is a genuine issue of material fact as to whether Groebner engaged in a situation

involving nonroutine stressful or strenuous physical law enforcement or other emergency

response activity during his final shift. Groebner responded to several emergency calls

during his shift, thus engaging in presumptively nonroutine law enforcement and

25
emergency response activity. That activity may have involved non-negligible physical

exertion and occurred under circumstances that posed or appeared to pose significant

danger and that provoked unusually high levels of alarm, fear, or anxiety in Groebner.

Because there remains a genuine issue of material fact, the ALJ erred by granting

summary disposition. See Pietsch, 683 N.W.2d at 306. We therefore affirm the court of

appeals holding—though using a different interpretation of “nonroutine”—that there is a

genuine issue of material fact as to whether Groebner engaged in a situation involving

nonroutine stressful or strenuous physical law enforcement or other emergency response

activity during his final shift.

II.

We next turn to the question of whether, if Groebner’s death does not meet the

presumption criteria under Minn. Stat. § 299A.41, subd. 3, Ms. Groebner may still prove

that he was “killed in the line of duty” under Kramer and Johnson, or whether the 2016

amendments’ presumption of compensability for certain heart-related deaths replaced the

Kramer and Johnson definition of “killed in the line of duty” for those types of deaths.

To answer this, we first review the facts and holdings of Kramer and Johnson and then

determine how the heart-related deaths presumption operates under Minn. Stat.

§ 299A.41, subd. 3.

A.

When we decided Kramer and Johnson in the 1980s, the Legislature had not

defined “killed in the line of duty” in the death benefits statute, other than to exclude

“deaths from natural causes” and “deaths that occur during employment for a private

26
employer.” Minn. Stat. § 352E.04 (1984).16 In Kramer and Johnson, we considered

whether the deceased officers’ heart-related deaths were “from natural causes” or should

be considered line-of-duty deaths.

In Kramer, a peace officer had a heart attack when he slipped walking down stairs

in the St. Paul Safety Building. 380 N.W.2d at 498. He suffered two more heart attacks

over the next 4½ years, the last resulting in his death. Id. at 498–99. His widow petitioned

for benefits under the death benefits statute using the theory that the last heart attack,

which occurred after the officer retired, was related to the first. Id. at 499. We noted the

purpose of the death benefits statute: “to provide a special lump sum award to spouses

and dependent children of peace officers in recognition of the unusual risks peace officers

face in their work” and “of a peace officer’s supreme sacrifice while performing

hazardous work in protection of the public.” Id. at 501 (citation modified). With the

statute’s purpose in mind, we interpreted “killed in the line of duty” to mean “death

resulting from the performance of those duties peculiar to a peace officer that expose the

officer to the hazard of being killed.” Id. We held that, although the officer was on duty

when he had the first heart attack, he was “engaged in the ordinary activity of

administrative office routine” and not “in a duty peculiar to peace officers that exposed

16
The statute was enacted as Minn. Stat. § 352E.04 (1973). Act of May 15, 1973, ch.
248, §§ 1–5, 1973 Minn. Laws 488, 489–91. The Legislature added “ ‘Killed in the line
of duty’ does not include deaths from natural causes or deaths that occur during
employment for a private employer” in 1984. Act of May 2, 1984, ch. 654, art. 2, § 126,
1984 Minn. Laws 1903, 1988. The Legislature recodified the statute to Minn. Stat.
§ 299A.41 in 1990. Act of May 4, 1990, ch. 591, art. 5, § 1, 1990 Minn. Laws 2291,
2311–12.

27
him to the hazard of being killed,” and so his survivors were not entitled to the death

benefits. Id. at 502.

We reiterated and clarified this definition of “killed in the line of duty” in Johnson,

431 N.W.2d 109. We consolidated appeals related to two firemen who suffered fatal

heart-related incidents while fighting fires. Id. at 111–12. One fireman had an “acute

rupture of an aneurysm of his ascending aorta” while “attaching a 55-pound hose” to the

bottom of a 1,000-gallon portable drop tank and was pronounced dead upon arriving at

the hospital. Id. The other fireman suffered a heart attack while attempting to neutralize

downed electrical wires, left the hospital a week later, suffered another attack later that

day, and died a few days later. Id. at 112. Experts testified that the emotional and physical

stress in fighting the fires contributed to both firemen’s deaths: one “died at the scene of

the fire as a result of his heart attack, while [the other] died a few days later as a direct

result of the heart attack he suffered at the fire.”17 Id. at 112, 114.

We concluded that, unlike the officer in Kramer who suffered a heart attack while

“performing administrative tasks,” the firemen “were involved in firefighting duties

which exposed them to the risk of being killed” “at the time of their heart attacks.” Id. at

114. We rejected the argument that the firemen’s deaths resulted from “natural causes”

under the death benefits statute. Id. at 114–15. We explained that “[w]e have never

17
Despite initially stating that the first fireman suffered “an acute rupture of an
aneurysm of his ascending aorta,” Johnson later categorized both firemen as suffering
from “heart attacks.” 431 N.W.2d at 112, 114. Whether the fireman died from a vascular
rupture or a heart attack is irrelevant to the operation of the death benefits statute.

28
defined the phrase ‘natural causes’ and do not find it to be a term of art which is

commonly defined,” and “any death which results in part from the performance of

[hazardous work in protection of the public] should qualify” for the death benefits.18 Id.

Thus, we held that the firemen’s “deaths were not the result of natural causes,” they

“were killed in the line of duty,” and their survivors were entitled to the death benefits.

Id.

Today, we emphasize that an officer is “killed in the line of duty” under Kramer

and Johnson when the officer’s death results in part from a specific instance of

performing hazardous work—not from the long-term stress of public safety work. In

Kramer, we characterized the death benefit as a payment made “in recognition of a peace

officer’s supreme sacrifice while performing hazardous work in protection of the public.”

380 N.W.2d at 501 (emphasis added). In Johnson, we concluded that the firemen died in

the line of duty because “at the time of their heart attacks both men were involved in

firefighting duties which exposed them to the risk of being killed.” 431 N.W.2d at 114.

Thus, an officer is “killed in the line of duty” under Kramer and Johnson if the officer’s

death results in part from a specific instance of performing duties peculiar to a public

18
We noted in Johnson that “[i]f the [L]egislature did not intend this result, it is free
to enact new clarifying legislation …. clearly defin[ing] any future exclusionary
language.” 431 N.W.2d at 115 n.3. The Commissioner argues that the Legislature enacted
the 2016 amendments in direct response to this footnote. Because the amendments were
enacted almost 30 years after we decided Johnson and none of the amendments’
legislative history mentions Johnson, this argument is unpersuasive.

29
safety officer that exposes the officer to the hazard of being killed. Kramer, 380 N.W.2d

at 501; Johnson, 431 N.W.2d at 114–15.

B.

The question remains whether the Legislature replaced the Kramer and Johnson

definition of “killed in the line of duty” for certain heart-related deaths by passing the

2016 amendments. To answer this question, we interpret Minn. Stat. § 299A.41, subd. 3,

to determine whether Kramer and Johnson still have a role to play within the current

statute’s heart-related deaths presumption framework.

The Commissioner and Ms. Groebner agree that the statute sets up a burden-

shifting framework where (1) the deceased officer’s estate has the burden to show that the

officer’s heart-related death meets the presumption criteria and, if the estate does so, (2)

the Commissioner has the burden to rebut that presumption with competent medical

evidence. The parties also agree that if the estate shows that the officer’s death meets the

presumption criteria and if the Commissioner either chooses not to present medical

evidence to the contrary or that evidence is insufficient to rebut the presumption, then the

officer was killed in the line of duty. The parties dispute how the statute operates when

the officer’s estate either cannot satisfy the presumption criteria or the Commissioner

successfully rebuts the presumption. The Commissioner argues that the inquiry ends, and

the officer was not “killed in the line of duty”; Ms. Groebner argues that the claimant can

still prove that the officer was “killed in the line of duty” under Kramer and Johnson.

To determine how the statute operates when the officer’s estate either cannot

satisfy the presumption criteria or the Commissioner successfully rebuts the presumption,

30
we again interpret Minn. Stat. § 299A.41, subd. 3. We focus on the statute’s

“presumption,” cognizant that we interpret “technical words and phrases and such others

as have acquired a special meaning … according to such special meaning or their

definition.” Minn. Stat. § 645.08(1). A legal word or phrase acquires a “special, technical

meaning” when “courts have ascribed a well-established and long-accepted meaning to

[the word or phrase].” Cox v. Mid-Minn. Mut. Ins. Co., 909 N.W.2d 540, 543–44 (Minn.

2018) (citations omitted) (internal quotation marks omitted) (holding “[i]n the context of

commencing a civil action, the word ‘delivery’ has a special meaning” and citing Black’s

Law Dictionary’s definition to determine the “accepted legal meaning of ‘delivery’ ”).

Here, Black’s Law Dictionary’s definition of “presumption” describes a burden-shifting

framework but does not explain what happens if the presumption criteria are not met or

the presumption is rebutted.19 Presumption, Black’s Law Dictionary (11th ed. 2019).

Looking at our “well-established and long-accepted meaning” of “presumption”

proves more helpful to our analysis. Cox, 909 N.W.2d at 543 (citation omitted) (internal

quotation marks omitted). Although we have never interpreted the presumption or

burden-shifting framework in Minn. Stat. § 299A.41, subd. 3, we have analyzed and

19
A legal inference or assumption that a fact exists because of the known or
proven existence of some other fact or group of facts. Most presumptions are
rules of evidence calling for a certain result in a given case unless the
adversely affected party overcomes it with other evidence. A presumption
shifts the burden of production or persuasion to the opposing party, who can
then attempt to overcome the presumption.

Presumption, Black’s Law Dictionary (11th ed. 2019).

31
applied presumptions and burden-shifting analyses in at least two other contexts:

statutory presumptions in workers’ compensation claims and McDonnell Douglas

burden-shifting in employment discrimination claims. See, e.g., Juntunen v. Carlton

County, 982 N.W.2d 729, 741 (Minn. 2022); Hanson v. Dep’t of Nat. Res., 972 N.W.2d

362, 373 (Minn. 2022). In both contexts, the claimant can prove its case even if the

presumption does not apply or is rebutted by the opposing party. In Juntunen, we

contemplated circumstances where an employee may maintain a claim for workers’

compensation benefits, even when the statutory presumption that the employee suffers

from an occupational disease does not apply to the claim or that presumption is rebutted.

982 N.W.2d at 741 (noting that “the employer faces a higher burden than in a case in

which no presumption applies” under the relevant statute and that, if the presumption is

“rebutted by the employer, the presumption disappears” (citation modified)). In Hanson,

an employment discrimination case, we noted that if the employer rebuts the presumption

of discrimination by offering a legitimate, nondiscriminatory reason for the adverse

employment action, the burden shifts back to the employee to show the employer’s

proffered reason is pretextual or improper. 972 N.W.2d at 373. That the claimant can

prove its case even if the presumption does not apply in both those burden-shifting

scenarios indicates that presumptions operate this way in general. In fact, neither we nor

the parties have identified any case where a successful rebuttal leaves the claimant with

no path forward.

Accordingly, the technical legal meaning of “presumption” includes a burden-

shifting framework where, if the presumption does not apply or is rebutted, the party

32
bringing the claim can still prove its case without the benefit of the presumption. The

technical meaning of “presumption” thus supports Ms. Groebner’s interpretation that, if

she is unable to show that Groebner’s death satisfies the presumption criteria, or if the

Commissioner successfully rebuts the presumption with competent medical evidence, she

can still prove that Groebner was “killed in the line of duty” under Kramer and Johnson.

The Commissioner argues, however, that reading the presumption language in

context with the whole statute supports its interpretation that a heart-related death can

only be a line-of-duty death if it satisfies the presumption criteria and the Commissioner

does not rebut the presumption with competent medical evidence. We read and construe

statutes “as a whole so as to harmonize and give effect to all its parts.” Riggs, 865

N.W.2d at 683 (citation omitted) (internal quotation marks omitted).

The 2016 amendments to Minn. Stat. § 299A.41, subd. 3, added both the “except

as provided in this subdivision” exception to the statute’s general exclusion of deaths

from natural causes and the heart-related deaths presumption. The Commissioner argues

that, in doing so, the Legislature designated “heart attack, stroke, [and] vascular rupture”

as natural-cause deaths that can only be line-of-duty deaths if they satisfy the

presumption criteria. The Commissioner asserts that designating these types of deaths as

categorically natural-cause deaths contradicted Kramer and Johnson’s holdings that any

death, including heart-related ones, are line-of-duty deaths and not natural-cause deaths if

they result in part from “the performance of those duties peculiar to a peace officer that

expose the officer to the hazard of being killed.” Johnson, 431 N.W.2d at 114 (quoting

Kramer, 380 N.W.2d at 501) (internal quotation marks omitted). Therefore, the

33
Commissioner argues, the 2016 amendments superseded Kramer and Johnson as to

deaths from heart attacks, strokes, and vascular ruptures.

However, the “except as provided in this subdivision” exception has meaning in

the statute without designating those types of deaths as natural-cause deaths. Two things

can be true: (1) a heart-related death that is a natural-cause death can only qualify for

benefits under the statute if they meet the presumption criteria “as provided in this

subdivision”; and (2) a heart-related death that is a line-of-duty death and not natural-

cause death under Kramer and Johnson can also qualify for benefits. The logic applies as

follows: a public officer dies from a heart attack. If the officer’s death meets the

presumption criteria and the Commissioner either chooses not to rebut the presumption or

attempts to do so unsuccessfully, that death may be a natural-cause death that meets the

“except as provided in this subdivision” exception. If the officer’s death either does not

meet the presumption criteria or the Commissioner successfully rebuts the presumption

with competent medical evidence, the ALJ then applies Kramer and Johnson to

determine whether the death was a line-of-duty death. If the ALJ concludes that the death

was a line-of-duty death under Kramer and Johnson, it was not a natural-cause death

excluded by the statute and it qualifies for benefits. If the ALJ concludes that the death

was not a line-of-duty death under Kramer and Johnson, the death does not qualify for

benefits—either because it is a natural-cause death excluded by the statute or because it

does not meet some other part of the “killed in the line of duty” definition.

Because the amended statute may be read consistent with Kramer and Johnson

and there is nothing in the statute or legislative history indicating that the 2016

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amendments were enacted to replace Kramer or Johnson, we reject the Commissioner’s

contention that the Legislature designated deaths from heart attacks, strokes, and vascular

ruptures categorically as natural-cause deaths and superseded Kramer and Johnson as to

those types of deaths. See Zephier v. Agate, 957 N.W.2d 866, 871 (Minn. 2021) (“We

presume that statutes are consistent with the common law and, we do not presume that

the Legislature intends to abrogate or modify a common law rule except to the extent

expressly declared or clearly indicated in the statute.” (citation omitted) (internal

quotation marks omitted)).

We hold that Minn. Stat. § 299A.41, subd. 3, creates a rebuttable presumption for

certain heart-related deaths that did not replace the Kramer and Johnson definition of

“killed in the line of duty” for those deaths. Under Minn. Stat. § 299A.41, subd. 3, a

public safety officer who dies from a heart attack, stroke, or vascular rupture was “killed

in the line of duty” if the death meets the statutory presumption criteria and, if the death

does not satisfy the presumption criteria or the Commissioner rebuts the presumption

with competent medical evidence, the officer’s estate can present its own medical

evidence to show that the officer was “killed in the line of duty” under Kramer and

Johnson. We therefore reverse the court of appeals holding that Kramer and Johnson do

not apply to deaths from heart attack, stroke, or vascular rupture.

* * *

Because the evidence viewed in the light most favorable to Ms. Groebner shows

that Groebner may have engaged in a situation involving nonroutine stressful or

strenuous physical law enforcement or other emergency response activity during his last

35
shift, we hold that there is a genuine issue of material fact, and the ALJ erred by granting

summary disposition. If, after an evidentiary hearing, the ALJ determines that Groebner’s

death did not satisfy the heart-related deaths presumption criteria or that the

Commissioner successfully rebutted the presumption with competent medical evidence,

Ms. Groebner can present her own medical evidence to show that Groebner was “killed

in the line of duty” under Kramer and Johnson.20

CONCLUSION

For the foregoing reasons, we affirm in part and reverse in part the decision of the

court of appeals and remand to the Court of Administrative Hearings for proceedings

consistent with this opinion.

Affirmed in part, reversed in part.

20
We acknowledge that the ALJ purported to apply Kramer and Johnson in its order
granting summary disposition. But the ALJ analyzed those cases in terms of whether
Groebner’s last shift “constitute[d] ‘nonroutine stressful or strenuous’ law enforcement
under Kramer and Johnson.” That was erroneous for two reasons. First, the “nonroutine
stressful or strenuous” language in Minn. Stat. § 299A.41, subd. 3, is specific to the
statutory presumption, while Kramer and Johnson control when the presumption does not
apply or has been rebutted. Those cases thus go to whether the officer was “killed in the
line of duty,” but not specifically as to whether—for purposes of the presumption—the
activity was “nonroutine stressful or strenuous.” Second, as we have explained, the ALJ
misapplied the “nonroutine stressful or strenuous physical” standard such that, contrary to
its holding, there is a genuine issue of material fact as to whether Groebner engaged in a
situation involving nonroutine stressful or strenuous physical law enforcement or other
emergency response activity. For these reasons, remand to the ALJ is appropriate here.

36