In the Matter of the Denial of Duty Death Benefits for Floyd Jones.

This opinion is nonprecedential except as provided by
Minn. R. Civ. App. P. 136.01, subd. 1(c).

STATE OF MINNESOTA
IN COURT OF APPEALS
A25-0443

In the Matter of
the Denial of Duty Death Benefits for Floyd Jones.

Filed September 29, 2025
Affirmed; motion denied
Jesson, Judge*

Office of Administrative Hearings
File No. 5-2400-40160

Daniel B. Harrison, Meuser, Yackley & Rowland, P.A., Eden Prairie, Minnesota (for
appellant)

Keith Ellison, Attorney General, Cassandra L. Buehler, Assistant Attorney General, St.
Paul, Minnesota (for respondent)

Considered and decided by Ross, Presiding Judge; Bond, Judge; and Jesson, Judge.
NONPRECEDENTIAL OPINION
JESSON, Judge
A firefighter passed away six years after retiring, and his surviving spouse sought a
death benefit designated for public safety officers killed in the line of duty. An
administrative law judge denied her benefit request. In this certiorari appeal, we must
determine whether the retired firefighter qualifies for the benefit. Because we conclude

* Retired judge of the Minnesota Court of Appeals, serving by appointment pursuant to
Minn. Const. art. VI, § 10.
2
that a statute defining the term killed in the line of duty is controlling, and under its plain
language the retired firefighter was not killed in the line of duty, we affirm.
FACTS
In 1992, the City of St. Paul hired Floyd Jones as a full-time firefighter. Jones began
as a firefighter/ emergency medical technician but later served as a hazardous material
specialist from 1994-1999, and as a fire engine operator for the remainder of his career. In
2013, Jones was diagnosed with hypertension and prostate cancer. He underwent a
prostatectomy and retired in 2014.
In 2019, Jones retained a doctor to evaluate him for disability and workers’
compensation benefits. The doctor believed that it was more likely than not that Jones’s
risk of developing prostate cancer increased due to his occupational exposure to chemicals
and smoke as a firefighter.
In August 2020, Jones fell twice and sustained some minor injuries. The next day,
he was found deceased in his home. The medical examiner concluded that the immediate
cause of death was probable myocardial infarction (heart attack) due to—or as a
consequence of— hypertension. The death certificate notes prostate cancer and macrocytic
anemia as other significant conditions contributing to death but not resulting in the
underlying cause of death. The manner of death was ruled natural. Jones was 59 years old
at the time of his death and had been retired for over six years.
Jones’s surviving spouse, the relator in this matter, sought a death benefit under
Minnesota Statutes section 299A.44 (2024), which requires the state to pay such a benefit
when a public safety officer is killed in the line of duty. She retained a doctor to analyze
3
her husband’s medical records and cause of death. The doctor determined that Jones
developed hypertension while working as a firefighter, and that it was likely that his
hypertension was caused by occupational psychosocial stress and smoke exposure from
firefighting. The doctor further opined that his hypertension was most likely a contributing
factor to his sudden cardiac death. Finally, the doctor concluded that his smoke exposure
as a firefighter was a contributing factor to the development of prostate cancer, and that the
stress and hormonal changes associated with the cancer contributed to his cardiovascular
disease.
Respondent Commissioner of the Department of Public Safety (the department)
denied relator’s application for the death benefit, and relator appealed to an administrative
law judge (ALJ). The parties filed cross-motions for summary disposition.
The ALJ denied relator’s motion, granted the department’s motion, and affirmed the
department’s decision to deny the benefit to relator. The ALJ concluded, as a matter of
law, that Jones was not a public safety officer at the time of his death and was not killed in
the line of duty.
This certiorari appeal followed.1
DECISION
Relator raises two challenges to the ALJ’s grant of summary disposition. First,
relator argues that the ALJ erred in determining that Jones was not a public safety officer
killed in the line of duty. Second, relator raises an equal-protection argument.

1 Following briefing to this court, the department moved to strike exhibits in relator’s reply-
brief addendum. We address that motion at the end of this opinion.
4
Before reaching relator’s arguments, we address the governing statutes and our
standard of review. The statute outlining the payment of the public safety officer death
benefit states as follows: “On certification to the governor by the commissioner of public
safety that a public safety officer employed within this state has been killed in the line of
duty, the commissioner of management and budget shall pay $100,000 from the public
safety officer’s benefit account” to a beneficiary. Minn. Stat. § 299A.44, subd. 1 (emphasis
added).
The term “public safety officer” is defined by statute to include a person employed
on a full-time basis “by a fire department of a governmental subdivision of the state, who
is engaged in . . . firefighting,” “emergency motor vehicle operation,” “the provision of
emergency medical services,” or is a “hazardous material responder.”
Minn. Stat. § 299A.41, subd. 4 (2024). The term “killed in the line of duty” is defined to
exclude deaths from natural causes, except in limited circumstances, one of which is a
death from a heart attack “sustained in the line of duty. ”
Minn. Stat. § 299A.41, subd. 3 (2024). The relevant part of the statute states:
(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 public safety officer, killed in the line of duty
includes the death of a public safety officer caused by
accidental means while the public safety officer is acting in the
course and scope of duties as a 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:
5
(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:
(i) while engaging or participating under clause (1);
(ii) while still on duty after engaging or participating
under clause (1); or
(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.

Id. (emphasis added).

With these statutory definitions in mind, we turn to our standard of review.
“Summary disposition is the administrative equivalent of summary judgment.”
Pietsch v. Minn. Bd. of Chiropractic Exam’rs, 683 N.W.2d 303, 306 (Minn. 2004).
Accordingly, we review a summary disposition from an ALJ “de novo to determine
whether there are any genuine issues of material fact and whether there was an error in
applying the law to the facts.” In re McCulloch, 980 N.W.2d 599, 604 (Minn. App. 2022)
(quotation omitted). In doing so, we view the evidence in the light most favorable to the
nonmoving party. In re Lannon, 984 N.W.2d 575, 580 (Minn. App. 2022).
The central issue in this appeal requires statutory interpretation, a matter which we
also review de novo. Hagen v. Steven Scott Mgmt., Inc., 963 N.W.2d 164, 169 (Minn.
2021). In that review, we try to “effectuate the intention of the legislature, reading the
6
statute as a whole.” Id. (quotation omitted). We look at the plain and ordinary meaning of
a statute’s words and phrases to see if the language is ambiguous, meaning it is “subject to
more than one reasonable interpretation.” Id. (quotation omitted). If the language is
unambiguous, we simply enforce it as written. Id.
Finally, we review alleged equal-protection violations de novo. State v. Holloway,
916 N.W.2d 338, 347 (Minn. 2018). With this background in mind, we turn to whether
Jones qualifies for the death benefit.
I. Jones does not qualify as a public safety officer killed in the line of duty.
While the ALJ, relying on the statutory definition of public safety officer,
determined that Jones did not qualify because he was not employed at the time of his death,
we do not need to reach the issue of whether he qualified in this regard. See
Minn. Stat. § 299A.41, subd. 4 (defining the term public safety officer). S ummary
disposition is equivalent to summary judgment, Pietsch, 683 N.W.2d at 306, and we will
affirm a grant of summary judgment if it can be sustained on any ground.
Winkler v. Magnuson, 539 N.W.2d 821, 828 (Minn. App. 1995), rev. denied (Minn. Feb.
13, 1996). To obtain the benefit, Jones not only needed to qualify as a public safety officer
but also establish that he was killed in the line of duty. See Minn. Stat. § 299A.44, subd. 1.
We conclude, as did the ALJ, that Jones was not killed in the line of duty.
To reach this conclusion, we turn to the statute defining “killed in the line of duty”
and three governing cases: Kramer v. State, Peace Officers Benefit Fund, 380 N.W.2d 497
(Minn. 1986); Johnson v. City of Plainview, 431 N.W.2d 109 (Minn. 1988); and Lannon,
984 N.W.2d 575.
7
As to the statute, at oral argument before this court, relator conceded that Jones does
not qualify under the natural-causes exception in Minnesota Statutes section 299A.41,
subdivision 3. We agree. Jones’s death certificate provides that he died of natural causes.
Again, the statutory definition of “killed in the line of duty” expressly excludes “deaths
from natural causes, except as provided.” Minn. Stat. § 299A.41, subd. 3. The statute
permits recovery for a heart-attack death, but the heart attack must be “sustained in the line
of duty.” Id. And the statute allows for a rebuttable presumption that a heart attack was
sustained in the line of duty if it occurred within 24 hours of strenuous duty-related
activities. Id. Simply put, Jones’s heart attack was not sustained in the line of duty, and
therefore he does not qualify under the natural-causes exception in the statute.
Rather than rely on the statutory natural-causes exception, relator contends that the
statute provides only a partial definition of the relevant term and that Jones was killed in
the line of duty under prevailing caselaw because his hypertension and cancer arose from
his firefighting duties and contributed to his death. To examine this assertion, we turn to
the intertwined history of the underlying statute and applicable caselaw.
Originally, the statute did not define the term killed in the line of duty, though it
expressly excluded heart-attack deaths. Minn. Stat. § 352E.04 (Supp. 1973). The supreme
court deemed that exclusion unconstitutional, Dependents of Ondler v. Peace Officers
Benefit Fund, 289 N.W.2d 486, 490 (Minn. 1980), and the legislature removed it .
1981 Minn. Laws ch. 356, § 354, at 1980. Then, in 1984, the legislature changed the statute
to exclude deaths from natural causes. 1984 Minn. Laws ch. 654, art. 2, § 126, at 1988.
8
Two years later, in Kramer, the supreme court 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.” 380 N.W.2d at 501 (emphasis added).
Applying that definition, the supreme court concluded that a detective was not killed in the
line of duty because he was performing ordinary administrative activities when he suffered
his first heart attack and was not “engaged in a duty peculiar to peace officers that exposed
him to the hazard of being killed.” Id. at 501-02.
The supreme court next applied this definition of “ killed in the line of duty” in
Johnson. In doing so, the supreme court specifically addressed the natural-causes
exclusion and held that a firefighter “who dies from a heart attack or complications related
to a heart attack, suffered while engaged in the hazards of firefighting” qualifies as being
killed in the line of duty, and such a death is not the result of natural causes “if firefighting
efforts were a substantial contributing cause of his death.” J ohnson, 431 N.W.2d at 111.
In that case, o ne firefighter collapsed while attaching a hose to a water tank and was
pronounced dead at the hospital. Id. at 111-12. Another firefighter “was rendered helpless
by severe chest pains” while working to neutralize downed electrical wires at the scene of
a fire. Id. at 112. The hospital released him a week later, but he suffered a major stroke
after arriving home and died a few days later. Id. The supreme court reiterated its
definition of “killed in the line of duty” from Kramer and applied it to the two firefighters,
concluding that both were killed in the line of duty. Id. at 114. The supreme court
distinguished the facts in Johnson from those in Kramer, explaining that “at the time of
9
their heart attacks both men were involved in firefighting duties which exposed them to the
risk of being killed.” Id.
In the years after Kramer and Johnson, the legislature enacted several amendments
“that clarified the parameters of the ‘natural causes’ exclusion . . . but did not otherwise
define ‘killed in the line of duty.’” Lannon, 984 N.W.2d at 584. In 2016, the legislature
created an exception for the natural-causes exclusion for certain heart attacks, strokes, and
vascular ruptures. 2016 Minn. Laws ch. 189, art. 14, § 3, at 1100.
It is the definition of killed in the line of duty developed in Kramer and applied in
Johnson that relator urges us to apply here, rather than the narrower statutory exception to
the natural-causes exclusion. We agree with relator that the statute provides only a partial
definition of the term “killed in the line of duty.” Indeed, in 2022 in Lannon, this court
held that “the supreme court’s definition of ‘killed in the line of duty’ in Kramer and
Johnson controls, except as to deaths specifically included or excluded by the legislature.”
984 N.W.2d at 585 (emphasis added).
But here, Jones ’s death has been specifically excluded by the legislature. His
immediate cause of death was a heart attack suffered over six years after his retirement
from firefighting, and his manner of death was ruled natural. Section 299A.41, subdivision
3 defines killed in the line of duty to exclude deaths from natural causes, except for deaths
that are “the direct and proximate result of a heart attack, stroke, or vascular
rupture . . . sustained in the line of duty,” a nd there is a rebuttable presumption that the
heart attack, stroke, or vascular rupture occurred in the line of duty if it occurs within 24
hours of the officer engaging in nonroutine, strenuous activity “while on duty.” While we
10
acknowledge the evidence that Jones’s firefighting career contributed to his early passing,
his heart attack was clearly not sustained in the line of duty. It is excluded under the plain
language of the statute . See id. (stating that the statute controls if a death is specifically
excluded).
Still, relator points to language in Kramer, which defined killed in the line of duty
to include deaths “resulting from the performance of those duties peculiar to a peace officer
that expose the officer to the hazard of being killed,” 380 N.W.2d at 501, and Johnson, in
which the supreme court held that “any death which results in part from the performance
of” hazardous work in protection of the public is compensable, 431 N.W.2d at 115. This
broad language encompasses the circumstances of Jones’s death, relator argues.
We are not persuaded. Both cases were issued prior to the amendments refining the
natural-causes exclusion. See 2016 Minn. Laws ch. 189, art. 14, § 3, at 1100. In Johnson,
the supreme court specifically relied on the fact that the legislature had provided no
parameters for the natural-causes exclusion. 431 N.W.2d at 114. Since Johnson , the
legislature did just that: it clarified the natural-causes exclusion by creating the natural-
causes heart-attack exception, 2016 Minn. Laws ch. 189, art. 14, § 3, at 1100 ; and as we
recognized in Lannon, that natural-causes exclusion controls. 984 N.W.2d at 585.
Finally, even if we applied Johnson—the more recent supreme court decision which
dealt specifically with the natural-causes exclusion—our decision would not differ. In
Johnson, in concluding that the deaths were not from natural cause s, the supreme court
relied on the close temporal and causal connection between the injuries suffered while
firefighting and the deaths. 431 N.W.2d. at 114. As the supreme court noted, “at the time
11
of their heart attacks both men were involved in firefighting duties.” Id. This case lacks
the same temporal and causal connection, as Jones’s death occurred six years after his
retirement.
In sum, while we appreciate the sacrifices that Jones made in his firefighting career,
we are bound by Lannon and the specific natural-causes exclusion set forth by the
legislature.
II. Relator fails to establish that section 299A.41, subdivision 3 is unconstitutional.

Relator argues that the natural-causes exception in section 299A.41, subdivision 3
violates the equal-protection clause because it differentiates based on the manner of death,
that is, the statute di stinguishes between a natural death from a respiratory attack and a
natural death from a heart attack.
The Equal Protection Clause of the United States Constitution provides: “No State
shall . . . deny to any person within its jurisdiction the equal protection of the laws.” U.S.
Const. amend. XIV, § 1. Similarly, the equal-protection guarantee in the Minnesota
Constitution provides: “No member of this state shall be disfranchised or deprived of any
of the rights or privileges secured to any citizen thereof, unless by the law of the land or
the judgment of his peers.” Minn. Const. art. I, § 2.
But to raise a valid challenge to the natural -causes exception in the statute, relator
must have standing to do so because, “[g]enerally, one does not have standing to assert the
constitutional rights of a third party.” In re Welfare of Child. of J.R.B., 805 N.W.2d 895,
906 (Minn. App. 2011) (quotation omitted), rev. denied (Minn. Jan. 6, 2012). Standing
requires that “(1) the party has suffered an injury-in-fact, or (2) the party is the beneficiary
12
of a legislative enactment granting standing.” Webb Golden Valley, LLC v. State, 865
N.W.2d 689, 693 (Minn. 2015). And the burden is on the party asserting a constitutional
violation to establish standing. United States v. Hays, 515 U.S. 737, 743 (1995). Here,
relator concedes that the statutory natural-causes exception does not apply to Jones. We
discern no injury-in-fact to relator via application of that exception. And relator otherwise
fails to establish a basis for standing in this instance.
Even if realtor had established standing to challenge the constitutionality of the
statute, the claim fails on the merits. The threshold issue in an equal-protection analysis
“is whether the claimant is treated differently from others to whom the claimant is similarly
situated in all relevant respects.” Holloway , 916 N.W.2d at 347 (quotation omitted). We
presume that relator’s two stated classes are similarly situated. But, as relator concedes
here, to survive constitutional scrutiny, only a rational- basis must exist to explain the
distinction between the two stated classes of people. See id. at 348 (applying rational-basis
review because there was not a suspect class or fundamental right at issue). Minnesota’s
rational-basis test, which is more stringent than the federal counterpart, requires that the
challenged distinction (1) “not be manifestly arbitrary or fanciful,” (2) that the challenged
classification be “genuine or relevant to the purpose of the law,” and (3) that “the purpose
of the statute must be one that the state can legitimately attempt to achieve.” Id. (quotation
omitted).
Here, the decision to differentiate between heart-attack deaths resulting from
specific instances of work-related stress and other work-related natural-cause deaths is
rational, i.e., there is a close connection between unusual work-imposed stress and a heart
13
attack suffered in close temporal relation to that work- imposed stress. See Johnson, 431
N.W.2d at 111-12 (addressing firefighter deaths from a ruptured aneurysm and heart attack
linked to the physical and emotional stress of firefighting ). The challenged distinction
satisfies Minnesota’s more stringent rational-basis test. This is particularly true given that
there is no fundamental right or suspect class at issue, and we therefore presume that the
statute is constitutional. Holloway, 916 N.W.2d at 347.
To persuade us otherwise, relator points to Ondler, but Ondler is distinguishable
because the firefighter there died of a heart attack while fighting a fire, and the
uncontradicted evidence established a causal connection between the firefighter’s death
and “the physical and psychic stress” from fighting the fire. 289 N.W.2d at 487. Indeed,
the state conceded that the firefighter in Ondler was killed in the line of duty. Id. at 489.
Here, we are presented with no such denial of the death benefit. Jones had been retired
over six years at the time of his death.
In conclusion, because the statutory definition of the term killed in the line of duty
is controlling, and relator’s equal-protection argument is unavailing, we affirm.
2
Affirmed; motion denied.

2 The department moved this court to strike exhibits from relator’s reply-brief addendum
because the exhibits “were not offered, received, or considered.” Because we did not
consider these exhibits in reaching our determinations, we deny the department’s motion
as moot. See Drewitz v. Motorwerks, Inc., 728 N.W.2d 231, 233 n.2 (Minn. 2007) (denying
as moot a motion to strike portions of an appellate brief because the reviewing court did
not rely on those portions).