In the Matter of the Denial of Line of Duty Death Benefits for Dallas Edeburn.

This opinion is nonprecedential except as provided by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
A25-0661

In the Matter of the Denial of Line of Duty Death Benefits for Dallas Edeburn.

Filed January 20, 2026
Affirmed
Larson, Judge
Dissenting, Reyes, Judge

Office of Administrative Hearings
File No. 22-2400-40186

Keith Ellison, Attorney General, Zoe Graham, Assistant Attorney General, St. Paul,
Minnesota (for relator Commissioner of Public Safety)

Daniel Harrison, Meuser, Yackley & Rowland, PA, Eden Prairie, Minnesota (for
respondent Jessica Edeburn)

Considered and decided by Frisch, Chief Judge; Reyes, Judge; and Larson, Judge.
NONPRECEDENTIAL OPINION
LARSON, Judge
In this certiorari appeal, relator, the commissioner of public safety, challenges an
administrative law judge’s (ALJ) decision that respondent, the survivor of Ramsey County
Deputy Dallas Edeburn, is eligible for a line-of-duty death benefit under Minn. Stat.
§ 299A.44 (2024). Under the statute, survivors are eligible for the benefit if a public safety
officer was “killed in the line of duty.” Id. The legislature has partially defined this phrase,
and the Minnesota Supreme Court has previously interpreted the phrase. The partial
statutory definition excludes “deaths from natural causes” except as provided in the
2

defining subdivision (the natural-causes exclusion). Minn. Stat. § 299A.41, subd. 3(a)
(2024). A provision within that subdivision identifies certain circumstances in which a
public safety officer who dies of a heart attack, stroke, or vascular rupture is “presumed to
have died as the direct and proximate result of a personal injury sustained in the line of
duty” (the heart-attack provision). Id. The presumption in the heart-attack provision is
subject to rebuttal by “competent medical evidence to the contrary.” Id., subd. 3(a)(3).
In this appeal , respondent concedes that Deputy Edeburn’s death does not satisfy
the heart-attack provision, but the parties disagree over whether respondent is otherwise
entitled to the line-of-duty death benefit. Resolving the parties’ disagreement requires us
to address two issues.
First, because “‘killed in the line of duty’ does not include deaths from natural
causes,” we must address the meaning of the phrase “natural causes” in the natural-causes
exclusion. See Minn. Stat. § 299A.41, subd. 3(a). The commissioner urges us to employ
a dictionary definition, while respondent argues that the supreme court has rejected that
approach in favor of a more nuanced understanding of the phrase under predecessors to the
current statute. Accordingly, we must determine whether the supreme court’s prior
interpretation of the phrase “natural causes” still applies, or if intervening statutory
amendments supersede the supreme court’s interpretation.
The second, related issue is the operation of the heart -attack provision. The
commissioner argues that the provision operates as the exclusive exception to the natural-
causes exclusion. Respondent argues that the provision merely creates a presumption to
3

aid survivors in establishing a right to the line-of-duty death benefit under certain
circumstances.
For the reasons set forth below, w e conclude that the supreme court’s definition of
“natural causes” continues to apply and that the heart-attack provision creates a rebuttable
presumption that an individual was “killed in the line of duty.” Accordingly, because the
parties do not dispute that respondent is entitled to the line-of-duty death benefit under the
statute as we interpret it, we affirm the ALJ’s decision.
FACTS

The following facts are derived from the record before the ALJ, viewed in the light
most favorable to the commissioner.1
In March 2021, Deputy Edeburn was involved in a high-speed motor vehicle
collision while on duty. Deputy Edeburn returned to work in December 2021 and was
placed on “light duty” while he continued to recover from posttraumatic stress disorder
(PTSD) and physical injuries.
On July 31, 2022, while still on “light duty,” Deputy Edeburn was working. His
coworkers last observed him at the patrol station around 2:30 p.m. He sent a text message
to respondent, his spouse, around 4:00 p.m., indicating that he was “on [his] way,” which
she understood to mean that he was coming home. He was not seen or heard from again

1 When reviewing a summary-disposition decision, we view the facts in the light most
favorable to the party against whom summary disposition was granted. Hanson v. Dep’t
of Nat. Res., 972 N.W.2d 362, 372 (Minn. 2022) (applying this standard on appeal from
summary judgment); Pietsch v. Minn. Bd. of Chiropractic Exam’rs, 683 N.W.2d 303, 306
(Minn. 2004) (explaining that “[s]ummary disposition is the administrative equivalent of
summary judgment”).
4

until 10:00 a.m. the next day, when his coworkers found him deceased in his work vehicle.
A medical examiner performed an autopsy and, in their report, listed Deputy Edeburn’s
immediate cause of death as “active lymphocytic myocarditis.”2
Respondent applied for the line-of-duty death benefit under section 299A.44. In
support of her application, respondent submitted a report from a board-certified medical
doctor in occupational medicine and public health, who concluded that “Edeburn’s work
as a police officer was a substantial contributing factor to his chronic stress, PTSD,
myocarditis, arrhythmia, and sudden death.” The report specifically cited the March 2021
motor-vehicle collision as a “substantial contributing factor to the development of [Deputy]
Edeburn’s myocarditis.”
The commissioner denied respondent’s application, determining that Deputy
Edeburn was not eligible for the line-of-duty death benefit because he was not “killed in
the line of duty” under the definition in section 299A.41, subdivision 3(a). Respondent
challenged the commissioner’s eligibility determination and requested a contested-case
hearing before the Court of Administrative Hearings.
3
After the Court of Administrative Hearings assigned an ALJ, the parties submitted
cross-motions for summary disposition. The ALJ granted respondent’s motion and denied
the commissioner’s motion. As relevant here, the ALJ concluded the supreme court’s

2 The report provided the following definition of myocarditis: “Myocarditis is a condition
characterized by inflammation of the myocardium, the main tissue of the wall of the heart.
This inflammation can involve the entire heart or be localized to specific areas.”
3 Effective August 1, 2025, the legislature changed the name of the Office of
Administrative Hearings to the Court of Administrative Hearings. See 2025 Minn. Laws
ch. 39, art. 2, § 17, at 1219 (amending Minn. Stat. § 14.48, subd. 1 (2024)).
5

interpretation of “killed in the line of duty” in previous versions of the death-benefit statute
controlled the meaning of the phrase. See Johnson v. City of Plainview, 431 N.W.2d 110
(Minn. 1988); Kramer v. State, Peace Officers Benefit Fund, 380 N.W.2d 497 (Minn.
1986). And, applying that interpretation, the ALJ determined Deputy Edeburn was “killed
in the line of duty,” and eligible for the line-of-duty death benefit under section 299A.44.
The commissioner appeals.
DECISION
Section 299A.44 requires that a $100,000 death benefit be paid to the survivors of
a public safety officer who the commissioner certifies has been “killed in the line of duty.”
If the commissioner denies a survivor’s application for the line-of-duty death benefit, the
survivor may request a contested-case hearing, and an ALJ then issues a final decision on
eligibility. See Minn. Stat. § 299A.43 (2024).
Here, the commissioner challenges the ALJ’s decision to grant respondent’s motion
for summary disposition and award her the line-of-duty death benefit. We apply the
Minnesota Administrative Procedure Act, Minn. Stat. §§ 14.001-.69 (2024), to review an
ALJ’s decision to grant summary disposition. Hy-Vee Food Stores, Inc. v. Minn. Dep’t of
Health, 705 N.W.2d 181, 184 (Minn. 2005). As relevant here, we may reverse or modify
an agency’s decision “if the substantial rights of the petitioners may have been prejudiced
because the administrative” decision is “affected by . . . [an] error of law.” Minn. Stat.
§ 14.69(d). In cases such as this, we review legal questions de novo. In re Wazwaz, 943
N.W.2d 212, 217 (Minn. App. 2020) , rev. denied (Minn. June 30, 2020). “[T]he party
challenging the [agency’s] decision” bears the burden “to show that the decision should be
6

reversed.” Fish v. Comm’r of Minn. Dep’t of Hum. Servs., 748 N.W.2d 360, 363 (Minn.
App. 2008).
Determining whether the ALJ erred requires us to interpret the statutory phrase
“killed in line of duty” in section 299A.41, subdivision 3(a), which includes interpreting
the phrase “natural causes.” We do not do so on a blank slate because the supreme court
has interpreted these terms in two cases addressing the line-of-duty death benefit under
previous versions of the statute. See Johnson, 431 N.W.2d at 110-15; Kramer, 380 N.W.2d
at 498-502; see also In re Lannon, 984 N.W.2d 575, 582-85 (Minn. App. 2022) (discussing
Kramer and Johnson).
In Kramer, the supreme court interpreted the phrase “killed in the line of duty ” in
addressing a claim for the line-of-duty death benefit under the 1980 version of the statute.4
380 N.W.2d at 498-99. There, a detective first suffered a heart attack while on duty
walking down the steps at the police station. Id. at 498. He suffered a second heart attack
two years later. Id. And, a year and a half after his retirement, he suffered a third, fatal
heart attack. Id. at 499. On appeal from a decision to grant his survivor the line-of -duty
death benefit, the supreme court was asked to interpret the phrase “killed in the line of
duty.” Id. at 499-502. The supreme court interpreted the phrase to mean “death resulting
from the performance of those duties peculiar to a [public safety] officer that expose the
officer to the hazard of being killed.” Id. at 501. And, applying that definition, the supreme
court concluded the detective was not “killed in the line of duty” because he was “engaged

4 The 1980 statute provided for a $50,000 death benefit to survivors of peace officers
“killed in the line of duty,” but did not define that term. See Minn. Stat. § 352E.04 (1980).
7

in the ordinary activity of administrative office routine , when he suffered his first heart
attack.” Id. at 501-02.
In Johnson, the supreme court interpreted the phrase “natural causes” in addressing
two claims for the line-of-duty death benefit under the 1985 version of the statute. 5 431
N.W.2d at 112. There, two firefighters suffered heart attacks at the scene of a fire. Id. at
111-12. One firefighter was pronounced dead at the hospital, the other was released from
the hospital but died a few days later. Id. On appeal from a decision to grant the survivors
the line-of-duty death benefit, the parties asked the supreme court to interpret the phrase
“natural causes.” Id. at 114. The supreme court held:
A peace officer who dies from a heart attack or complications
related to a heart attack, suffered while engaged in the hazards
of firefighting, is “killed in the line of duty” under Minn. Stat.
§ 352E.04 (1985), and his death is not the result of “natural
causes” if firefighting efforts were a substantial contributing
cause of his death.

Id. at 110 (syllabus). Applying its interpretation of the phrase “natural causes,” the
supreme court concluded the heart attacks the firefighters suffered “were not the result of
natural causes.” Id. The supreme court reasoned:
[The firefighters’] deaths were not the result of natural causes.
Although both men were suffering from atherosclerosis,
neither was aware of this condition. In addition, expert
testimony indicated that the physical and emotional stress
associated with their firefighting activities was a contributing
factor in the heart attacks each man suffered. Given that the

5 The 1985 statute provided for a $100,000 death benefit to survivors of peace officers
“killed in the line of duty” and provided that “‘[k]illed in the line of duty’ does not include
deaths from natural causes or deaths that occur during employment for a private employer
other than an independent nonprofit firefighting corporation.” Minn. Stat. § 352E.04
(Supp. 1985).
8

Fund was established to recognize the sacrifices made by peace
officers in performing hazardous work in protection of the
public, any death which results in part from the performance
of such work should qualify for Fund benefits.

Id. at 114-15 (emphasis added). In a footnote, the supreme court stated, “[i]f the legislature
did not intend this result, it is free to enact new clarifying legislation,” and urged the
legislature to “clearly define any future exclusionary language.” Id. at 115 n.3 (emphasis
added).
In the years following Kramer and Johnson, the legislature made several
amendments to the statutory scheme governing the death benefit. 6 Most pertinent to our
analysis, in 2016, the legislature amended section 299A.41, subdivision 3, to add the heart-
attack provision. See 2016 Minn. Laws ch. 189, art. 14, § 3, at 1100. 7 As currently
codified, the statute provides:
“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,

6 In 1990, the legislature recodified the statute and moved the natural-causes exclusion
from the “Disbursements” section, recodified at Minn. Stat. § 299A.44 (1990), to the
“Definitions” section, recodified at Minn. Stat. § 299A.41, subd. 3 (1990). See 1990 Minn.
Laws ch. 591, art. 5, §§ 1, 4, at 2311-13. The recodification made no changes to the
“natural causes” language that previously appeared in the “Disbursements” section. See
id.; see also Minn. Stat. § 299A.41, subd. 3 (1990) (“‘Killed in the line of duty’ does not
include deaths from natural causes”). Two years later, the legislature amended the “killed
in the line of duty” partial definition in subdivision 3 to include certain accidental deaths
(the accidental-death provision). 1992 Minn. Laws ch. 523, § 1, at 1317-18.
7 In the same law, the legislature amended the accidental-death provision to include “public
safety officers,” rather than just “peace officers.” See id.
9

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 . . . [listed criteria].

Minn. Stat. § 299A.41, subd. 3(a).
In 2022, our court was asked to apply the phrase “killed in the line of duty” in the
context of a death by suicide. Lannon , 984 N.W.2d at 578-80. There, the suicide was
directly traceable to PTSD caused by the public safety officer performing duties peculiar
to that position. Id. at 585. After noting the statute only provides a partial definition of
“killed in the line of duty,” we concluded 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 in Minn. Stat. § 299A.41, subd. 3.” Id. We then concluded
that, because the statute neither included nor excluded deaths by suicide, Kramer controlled
the analysis. Id. And because a death by suicide could result “from the performance of
those duties peculiar to a [public safety] officer that expose the officer to the hazard of
being killed,” we concluded the phrase “killed in the line of duty” included eligible deaths
by suicide.
8 Id.
To resolve this case, we must determine the meaning of the phrase “natural causes”
in the natural-causes exclusion. 9 Broadly, the commissioner argues we should apply the

8 In Lannon, we addressed Minn. Stat. § 299A.41, subd. 3 (2022). Following our decision
in Lannon, the legislature amended subdivision 3, moving its existing language into
subdivision 3(a) and adding subdivision 3(b) to expressly include certain deaths by suicide.
2023 Minn. Laws ch. 52, art. 5, § 14, at 89 -90. Thus, the discussion of subdivision 3 in
Lannon addresses the same language that we address as subdivision 3(a) in this opinion.
9 The department does not challenge the ALJ’s conclusion that the performance of duties
peculiar to a public safety officer were a substantial contributing cause of Deputy

10

dictionary definition and conclude the phrase plainly means any “death from causes other
than accident or violence.” See Black’s Law Dictionary 502 (12th ed. 2024) (defining
natural death). Respondent disagrees, arguing that we are bound by the supreme court’s
interpretation of the phrase “natural causes” in Johnson that “a death is not the result of
‘natural causes’ if [the duties peculiar to a public safety officer] were a substantial
contributing cause of [the public safety officer’s] death.” 431 N.W.2d at 110 (syllabus).
We agree with respondent.
The supreme court has explained that, once it has interpreted a statute, that prior
interpretation guides future disputes over the meaning of the statute. Hagen v. Steven Scott
Mgmt., Inc., 963 N.W.2d 164, 174 (Minn. 2021). The supreme court’s interpretation
“becomes part of the statute as though written therein,” id. (citation omitted), and stare
decisis “has special force . . . because the Legislature is free to alter what [the supreme
court has] done,” Koehnen v. Flagship Marine Co., 947 N.W.2d 448, 453 (Minn. 2020)
(citation omitted). See also Minn. Stat. § 645.17 (2024) (explaining that “when a court of
last resort has construed the language of a law,” courts may presume that the legislature
intends for the same construction to apply in subsequent laws on the same subject matter).
If we conclude that the supreme court’s prior interpretations remain in force, we need not
undertake any independent interpretative efforts; indeed, we are precluded from doing so.

Edeburn’s death. And respondent does not challenge that Deputy Edeburn’s death does
not meet the requirements set forth in the heart-attack provision. As such, these arguments
are forfeited. See Jundt v. Jundt, 12 N.W.3d 201, 204 (Minn. App. 2024), rev. denied
(Minn. Dec. 31, 2024). Thus, the resolution of this case hinges on our interpretation of the
phrase “natural causes” in the natural-causes exclusion.
11

See State v. Curtis, 921 N.W.2d 342, 346 (Minn. 2018) (“The court of appeals is bound by
supreme court precedent.”).
As described above, in Johnson, the supreme court interpreted the phrase “natural
causes” and held that a death is not the result of natural causes if the duties peculiar to a
public safety officer “were a substantial contributing cause” of the public safety officer’s
death. 431 N.W.2d at 110 (syllabus).10 After Johnson, the legislature recodified the line-
of-duty death-benefit statute into a different statutory chapter and moved the natural-causes
exclusion from the section providing the benefit to a definitions section. The legislature
later added the heart-attack provision and added a clause to the end of the natural-causes
exclusion, so that it now reads: “Killed in the line of duty does not include deaths from
natural causes, except as provided in this subdivision.” Minn. Stat. § 299A.41, subd. 3(a).
But none of these post-Johnson legislative amendments redefined the phrase “natural

10 The department argues that Johnson did not define the phrase “natural causes.” But in
the syllabus, the supreme court explicitly interpreted the phrase. Id. at 110. A case’s
syllabus “summarizes the [authoring court’s] holding.” Albright v. Henry, 174 N.W.2d
106, 111 (Minn. 1970). The Minnesota Supreme Court authors its own syllabi. Sharood
v. Hatfield, 210 N.W.2d 275, 280 (Minn. 1973); see also Minn. Stat. § 480.06 (2024) (“In
all cases decided by the [supreme] court, it shall give its decision in writing . . . together
with headnotes, briefly stating the points decided.”). Therefore, it may be cited as legal
authority. See Albright, 174 N.W.2d at 111 (quoting syllabus as authority); Sefkow v.
Sefkow, 427 N.W.2d 203, 214 (Minn. 1988) (citing syllabus of a prior opinion as authority).
Further, in the body of the Johnson opinion, the supreme court explicitly concluded that
the two firefighters’ “deaths were not the result of natural causes” because “any death
which results in part from the performance of [hazardous work for the protection of the
public] should qualify for” the line-of-duty death benefit. Johnson, 431 N.W.2d at 114-15
(emphasis added). Therefore, we are not persuaded that the supreme court did not interpret
the phrase “natural causes” in Johnson.
12

causes,” despite the supreme court’s invitation for the legislature to supersede Johnson
with clarifying language if the conclusion in Johnson was not the legislature’s intent.
The commissioner disagrees, arguing the legislature redefined the phrase “natural
causes” when it added the “except as provided in this subdivision” language and the heart-
attack provision. 11 According to the commissioner, these changes plainly indicated the
legislature intended to redefine the phrase “natural causes” to mean the dictionary
definition—an interpretive tool expressly rejected in Johnson. 431 N.W.2d at 114 (stating
the phrase “natural causes” is not “a term of art which is commonly defined”). We are not
persuaded for two reasons.
First, the heart-attack provision operates as a rebuttable “presumption.” As set forth
above, the heart-attack provision provides that “[k]illed in the line of duty also means” a
public safety officer “shall be presumed to have died as the direct and proximate result of

11 The commissioner relies on language in Lannon stating that “[t]he legislature’s
subsequent enactment of Minn. Stat. § 299A.41, subd. 3, and revisions to that provision,
clarified the exclusion of deaths from natural causes” but did not “supersede the
overarching interpretation adopted by the supreme court.” 984 N.W.2d at 585. But,
because Lannon involved a death by suicide, we were not required in that case to interpret
the phrase “natural causes.” The department also relies on our nonprecedential opinions
in In re Groebner, No. A24-1410, 2025 WL 1430594, at *1 (Minn. App. May 19, 2025),
rev. granted (Minn. Aug. 27, 2025), and In re Jones, No. A25-0443, 2025 WL 2752621,
at *1 (Minn. App. Sept. 29, 2025), rev. granted (Minn. Dec. 17, 2025). These opinions are
not binding, and we do not find them persuasive on this issue. See Minn. R. Civ. P. 136.01,
subd. 1(c). Groebner did not require this court to define the phrase “natural causes”
because the issue in Groebner was whether the requirements for the heart-attack provision
were met. 2025 WL 1430594, at *3. In Jones, we concluded that a firefighter’s heart
attack, which occurred six years after his retirement, was specifically excluded by the
statute because it did not meet the requirements of the heart-attack provision. 2025 WL
2752621, at *5. But we also concluded that the firefighter’s death would not meet the
“natural causes” definition set forth in Johnson. Id.
13

a personal injury sustained in the line of duty” if they “die[] as the direct and proximate
result of a heart attack, stroke, or vascular rupture” and meet certain listed criteria . Minn.
Stat. § 299A.41, subd. 3(a) (emphasis added). The word “presume” means “[t]o accept
something as true until it is shown not to be true.” Black’s Law Dictionary 1435 (12th ed.
2024) (defining presume). Thus, the heart- attack provision’s plain language does not
indicate any intent to alter the meaning of the phrase “natural causes” in the natural-causes
exclusion.
Second, the addition of the phrase “except as provided in this subdivision” does not
offer a new definition of the phrase “natural causes” or indicate an intent to alter the
supreme court’s prior interpretation. Instead “natural causes” retains the same meaning
provided in Johnson and exceptions to the natural-causes exclusion only arise from the
statute. Our conclusion aligns with the timing of the addition of the phrase, which the
legislature added when it included the heart-attack provision. Thus, the legislature may
have understood that certain circumstances may not qualify as a “natural cause” death
under Johnson, yet a survivor may nonetheless be entitled to benefits under the
presumption. Accordingly, we are not convinced that the legislature intended to alter the
supreme court’s interpretation of “natural causes” when it added the phrase “except as
provided in this subdivision.”
In sum, and for the foregoing reasons, we must “presume that the Legislature
intended for [the supreme court’s] interpretation . . . to be placed upon the current statutory
language.” Keystone Twp. v. Red Lake Watershed Dist., 20 N.W.3d 612, 621 (Minn. 2025).
This is especially so because the supreme court directed that the legislature should “clearly
14

define any future exclusionary language” if it did not intend the result in Johnson. See 431
N.W.2d at 115 n.3 (emphasis added). Therefore, we must follow the supreme court’s
precedent and conclude that a death is not the result of “natural causes” if the duties peculiar
to a public safety officer “were a substantial contributing cause of [the public safety
officer’s] death.” Id. Because the commissioner does not challenge the ALJ’s
determination that Deputy Edeburn’s professional duties were a substantial contributing
cause of his death, we conclude the ALJ correctly determined respondent is entitled to the
line-of-duty death benefit.
While we conclude the supreme court’s interpretation in Johnson is controlling, we
note that we would reach the same result if we applied our principles of statutory
interpretation. “The object of all interpretation and construction of laws is to ascertain and
effectuate the intention of the Legislature.” City of Brainerd v. Brainerd Invs. P’ship, 827
N.W.2d 752, 755 (Minn. 2013); see also Minn. Stat. § 645.16 (2024). “When legislative
intent is clear from the statute’s plain and unambiguous language, we interpret the statute
according to its plain meaning.” City of Brainerd, 827 N.W.2d at 755. “We do not resort
to extrinsic sources when interpreting a statute unless the statute is ambiguous.” Id. at 757.
A statute is ambiguous if “the statutory language is susceptible to more than one reasonable
interpretation.” Spann v. Minneapolis City Council, 979 N.W.2d 66, 73 (Minn. 2022)
(quotation omitted). Here, we would conclude the phrase “natural causes” is ambiguous
because both parties offer reasonable interpretations.
As explained above, the commissioner relies on a dictionary definition to contend
that the phrase “natural causes” means any “death from causes other than accident or
15

violence.” See Black’s Law Dictionary 502 (12th ed. 2024) (defining natural death). And,
according to the commissioner, the heart-attack provision operates as the sole “exception”
to the natural-causes exclusion. Thus, the commissioner argues that public safety officers
who previously qualified under Johnson are not entitled to the line- of-duty death benefit
unless they satisfy the criteria in the heart-attack provision. We conclude the
commissioner’s proposed interpretation is reasonable because the supreme court often
relies on dictionaries to interpret undefined terms. McBee v. Team Indus., Inc., 26 N.W.3d
847, 853 (Minn. 2025) (“When the Legislature has not defined a statutory term, we may
consider dictionary definitions to determine the term’s common usage, and when legal
terms are referenced in statutes we often look to legal dictionaries.”).
Respondent contends that “natural causes” means deaths where the duties peculiar
to a public safety officer were not a substantial contributing cause of their death. Further,
relying on the legislature’s use of the word “presumed,” respondent argues the heart-attack
provision operates—primarily—as a presumption. Accordingly, respondent reasons that
the legislature intended to make it easier for certain survivors to qualify for the line-of-duty
benefit when it added the heart-attack provision. Given the context of the statute and the
supreme court’s prior determination that the phrase “natural causes” is not a “term of art
which is commonly defined,”
12 we conclude the more nuanced interpretation presented by
respondent is also reasonable. See State v. Scovel, 916 N.W.2d 550, 555 (Minn. 2018)
(“[I]t is one of the surest indexes of a mature and developed jurisprudence not to make a

12 The supreme court expressly rejected interpreting the phrase “natural causes” to mean
“only deaths caused solely by an external force” in Johnson. 431 N.W.2d at 114.
16

fortress out of the dictionary” (quoting Cabell v. Markham, 148 F.2d 737, 739 (2d Cir.
1945)); Buzzell v. Walz, 974 N.W.2d 256, 261 (Minn. 2022) (explaining that the “specific
meaning of a word depends on how it is being used in context” (quotation omitted)).
When a statute is ambiguous, we may consider the post- ambiguity canons of
construction13 and other indicia of legislative intent. See Spann, 979 N.W.2d at 73; Minn.
Stat. § 645.16. These include:
(1) the occasion and necessity for the law;
(2) the circumstances under which it was enacted;
(3) the mischief to be remedied;
(4) the object to be attained;
(5) the former law, if any, including other laws upon the
same or similar subjects;
(6) the consequences of a particular interpretation;
(7) the contemporaneous legislative history; and
(8) legislative and administrative interpretations of the
statute.

Minn. Stat. § 645.16.
Beginning with “the occasion and necessity for the law,” the purpose of the line-of-
duty death benefit is “to recognize the sacrifices made by [public safety] officers in
performing hazardous work in protection of the public.” Johnson, 431 N.W.2d at 115.
And with respect to the “former law,” over the years, the legislature has consistently
expanded the definition of “killed in the line of duty,” making a greater—not a fewer —
number of survivors eligible for the line-of -duty death benefit. 14 Accordingly, the

13 The supreme court distinguishes between pre- and post-ambiguity canons of
construction. See State v. Lee, 22 N.W.3d 608, 614 (Minn. App. 2025).
14 See 1985 Minn. Laws 1st Spec. Sess. ch. 7, § 10, at 1656 (expanding coverage for deaths
from certain private employers); 1992 Minn. Laws ch. 523, § 1, at 1317-18 (expanding

17

legislature has over time demonstrated its intent that more survivors receive this benefit,
counseling against the commissioner’s proposed interpretation.
Moving to “the mischief to be remedied,” “object to be attained,” and “the
contemporaneous legislative history,” all the legislative history surrounding the addition
of the heart-attack provision indicates that the legislature intended to “expand” eligibility
for the line-of -duty death benefit. Both the House and Senate research departments
described the addition of the heart-attack provision as an “expansion” of coverage. Minn.
H.R. Rsch. Dep’t, B. Summary of H.F. No. 2810 (Mar. 22, 2016) (noting the amendment
“expands coverage to officers who die from work-connected heart attacks, strokes, and
vascular ruptures”); Minn. S. Rsch. Dep’t, B. Summary of S.F. No. 2743 (Mar. 23, 2016)
(stating that the inclusion of the heart-attack provision “expands the definition of ‘killed in
the line of duty’”). During the hearings on whether the legislature should add the heart-
attack provision, supporters testified that its purpose was to lessen the burden of proof for
families to obtain the benefit. E.g., Hearing on H.F. No. 2810 Before the H.R. Pub. Safety
& Crime Prev. Pol’y & Fin. Comm. (Mar. 22, 2016) (statements of Rep. Howe & Chris
Parsons, President, Minn. Pro. Firefighters); Hearing on S.F. No. 2743 Before the S.
Judiciary Comm. (Mar. 22, 2016) (statements of Sen. Pappas & Michael Smith, President,
St. Paul Firefighters Union). And, at the time the legislature was considering the
amendment, it was aware that the bill carried a fiscal note. Minn. Dep’t of Pub. Safety,

coverage for certain accidental deaths); 2016 Minn. Laws ch. 189, art. 14, § 3, at 1100
(expanding coverage to cover more accidental deaths and adding the heart-attack
provision); 2023 Minn. Laws ch. 52, art. 5, § 14, at 67 (expanding coverage to include
certain deaths by suicide).
18

Fiscal Note on H.F. 2810, HF2810-0-Pub. Safety Officer Death Benefits Mod (Mar. 29,
2016). The fiscal note indicated that, prior to 2016, the fund predicted approximately
“2 payouts” per year. Id. at 2. But, if the bill was passed, the assumed number of payouts
would double. Id. In all the legislative history, we have found no indication that the
legislature intended that a public safety officer who qualified for the line-of-duty death
benefit before the adoption of the heart-attack provision would no longer be eligible. This
intent to expand coverage and lower the burden of proof for survivors also counsels against
the commissioner’s proposed interpretation that the legislature narrowly defined the phrase
“natural causes” when it adopted the heart-attack provision.
Finally, considering the “consequences of a particular interpretation,” we would not
adopt the commissioner’s proposed interpretation because it potentially poses a
constitutional problem. “If a statute is ambiguous, the construction that avoids
constitutional problems should be used, even if such a construction is less natural.”
Olmanson v. LeSueur County, 693 N.W.2d 876, 879 (Minn. 2005).
In Dependents of Ondler v. Peace Officers Benefit Fund, the supreme court
addressed the constitutionality of a statutory provision that excluded from eligibility for
the line-of-duty death benefit deaths resulting from heart attacks.
15 289 N.W.2d 486, 489-
90 (Minn. 1980). The supreme court concluded that the provision violated the Equal
Protection Clause. Id. at 489. The supreme court reasoned that there was no rational basis

15 In Ondler, the supreme court addressed a claim for the line-of- duty death benefit under
the 1978 version of the statute. Minn. Stat. § 352E.04 (1978). The statute provided for a
$50,000 payment to eligible survivors and provided, in relevant part, that “killed in the line
of duty shall not include any peace officer who dies as a result of a heart attack.” Id.
19

for solely excluding heart attacks from the line-of-duty death benefit, because “the same
stresses which triggered Ondler’s heart attack could have caused respiratory failure, such
as an acute asthma attack, and several types of strokes, including aneurysms, in persons
susceptible to such occurrences.” Id. Thus, because Ondler would have been eligible for
the benefit if his “death resulted from any of these other causes,” there was no rational
basis for the exclusion. Id.
Here, the commissioner’s proposed interpretation presents a similar problem. The
commissioner contends that all “death[s] from causes other than accident or violence” are
excluded from the line -of-duty death benefit, with an exception for certain deaths caused
by “heart attack, stroke, or vascular rupture.” But this creates the same problem identified
in Ondler. “[T]he same stresses which trigger[]” a heart attack or stroke, could cause
respiratory failure, an asthma attack, or, even myocarditis. Id. Adopting respondent’s
proposed interpretation avoids this potential constitutional issue.
For these reasons, even if we concluded that Johnson was not controlling, we would
still interpret the natural-causes exclusion consistent with its holding.
Affirmed.

REYES, Judge (dissenting)
Relator Commissioner of the Minnesota Department of Public Safety (the
department) argues that an administrative-law judge (ALJ) erred by granting summary
disposition to respondent survivor of Deputy Dallas Edeburn by determining that he was
“killed in the line of duty” when he died of active lymphocytic myocarditis because that
cause of death is not expressly included or excluded under Minn. Stat. § 299A.41, subd. 3
(2024).1 The department argues that : (1) the plain and unambiguous language of this
subdivision “does not include deaths from natural causes” in the definition of “killed in the
line of duty” and Deputy Edeburn died from natural causes; (2) “active lymphocytic
myocarditis” is not a heart attack, stroke, or vascular rupture, which would have raised a
rebuttable presumption that a person “died as the direct and proximate result of a personal
injury sustained in the line of duty” and was “killed in the line of duty,” but only if certain
requirements were met; and (3) even if Deputy Edeburn had died from a heart attack,
stroke, or vascular rupture—which he did not —respondent’s claim would still fail because
Deputy Edeburn did not participate in nonroutine stressful or strenuous physical law-
enforcement activity within 24 hours of his death. I agree with the department and would
reverse and remand. I therefore respectfully dissent.

1 I cite the most recent version of this statute because it has not been amended in relevant
part. But see Interstate Power Co. v. Nobles Cnty. Bd. of Comm’rs, 617 N.W.2d 566, 575
(Minn. 2000) (stating that, generally, “appellate courts apply the law as it exists at the time
they rule on a case”). Although the legislature amended the statute after Deputy Edeburn’s
2022 death, see 2023 Minn. Laws ch. 52, art. 5, § 14, at 877-78, the amendment does not
change the substance of the applicable section, but only renumbers the statute and adds an
additional subsection.

D-2

The department challenges the ALJ’s grant of summary disposition. “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). “Summary
disposition is appropriate only when there is no genuine issue as to any material fact and
the moving party is entitled to judgment as a matter of law.” In re Lannon, 984 N.W.2d
575, 580 (Minn. App. 2022). Appellate courts review an ALJ’s grant of summary
disposition de novo to “determin[e] whether there are any genuine issues of material fact
and whether there was an error in applying the law to the facts.” Pietsch v. Minn. Bd. of
Chiropractic Exam’rs, 683 N.W.2d 303, 306 (Minn. 2004). “In doing so, we view the
evidence in the light most favorable to the nonmoving party” here, the department.
Lannon, 984 N.W.2d at 580.
I. The ALJ erred by granting summary disposition to respondent because it
misinterpreted and misapplied caselaw.

Respondent argues that supreme court definitions from 1986 and 1988 cases control
because “killed in the line of duty” is not defined by the statute. I disagree.
Appellate courts review the interpretation of a statute de novo. In re NorthMet
Project Permit to Mine Application, 959 N.W.2d 731, 744 (Minn. 2021). The main goal
of statutory interpretation “is to ascertain and effectuate the intention of the legislature.”
Minn. Stat. § 645.16 (2024). “Every law shall be construed, if possible, to give effect to
all its provisions.” Id.; see also Hagen v. Steven Scott Mgmt., Inc., 963 N.W.2d 164, 169
(Minn. 2021) (explaining that statutory interpretation requires appellate courts to “read[]
the statute as a whole”).

D-3

Statutory “words and phrases are construed according to rules of grammar and
according to their common and approved usage.” Minn. Stat. § 645.08(1) (2024). “When
a statute is unambiguous, we interpret it according to the plain meaning of its text.” Pfoser
v. Harpstead, 939 N.W.2d 298, 310 (Minn. App. 2020) (quotation omitted), aff’d, 953
N.W.2d 507 (Minn. 2021). “A statute is ambiguous when its language is subject to more
than one reasonable interpretation.” State v. Riggs, 865 N.W.2d 679, 682 (Minn. 2015).
This court recently outlined the history of section 299A.41, subdivision 3, and the
death-benefit statute. See Lannon, 984 N.W.2d at 581, 583-84. We noted that the
legislature amended th e statute several times since its enactment in 1973. Id. at 581. I
highlight a few of the relevant amendments. In 1984, the legislature defined “killed in the
line of duty” by what it does not include, stating in part: “‘Killed in the line of duty’ does
not include deaths from natural causes.” 1984 Minn. Laws ch. 654, art. 2, § 126, at 1988.
In 1990, the legislature recodified the death- benefit statute and moved this language to a
new “definitions” section. See 1990 Minn. Laws ch. 591, art. 5, § 1, at 2311-13. From that
point through 2024, the legislature expanded the statute’s coverage by adding in language
to cover, if certain requirements are met, (1) accidents, see 1992 Minn. Laws ch. 523, § 1,
at 1317-18; (2) relevant to our analysis, heart attacks, strokes, and vascular ruptures from
the natural-causes exclusion, see 2016 Minn. Laws ch. 189, art. 14, § 3, at 1100; and
(3) deaths by suicide, see 2023 Minn. Laws ch. 52, art. 5, § 14, at 877-78.
In dispute here are the effects of the changes the legislature made to the statute after
two supreme court cases, Kramer v. State, Peace Officers Benefit Fund, 380 N.W.2d 497

D-4

(Minn. 1986) and Johnson v. City of Plainview, 431 N.W.2d 109 (Minn. 1988). Before
analyzing these changes, I provide a brief overview of Kramer and Johnson.
Kramer defined “‘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.” 380 N.W.2d at 501. In doing so, the supreme court rejected the definition
of “killed in the line of duty” proposed by the Workers’ Compensation Court of Appeals
(WCCA), which required that the officer’s “employment as a peace officer was a
substantial, contributing cause of his death.” Id. at 499, 501; see also id. at 502 (Scott, J.,
dissenting) (describing WCCA ruling). Ultimately, the officer in Kramer did not qualify
for death benefits because the causal chain leading to his death originated with a heart
attack suffered while walking down steps and, even though he was “on duty” at the time,
walking down steps was not “a duty peculiar to” his employment. See id. at 502 (majority
opinion).
The supreme court in Johnson did not expand or change Kramer’s definition of
“killed in the line of duty.” Instead, Johnson carved out an exception to the statutory
exclusion for natural-cause deaths. See 431 N.W.2d at 114 (distinguishing Kramer). As
the majority notes, the second syllabus point in Johnson states: “A peace officer who dies
from a heart attack or complications related to a heart attack, suffered while engaged in the
hazards of firefighting, is ‘killed in the line of duty’ under Minn. Stat. § 352E.04 (1985),
and his death is not the result of ‘natural causes’ if firefighting efforts were a substantial
contributing cause of his death.” Id. at 110 (syllabus). This is a narrow exception to the
Johnson-era statute’s natural-causes exclusion, with the following requirements: (1) the

D-5

decedent must be a peace officer; (2) who suffered a heart attack “while engaged in the
hazards of” being a peace officer ; (3) who died “from a heart attack or complications
related to a heart attack;” and (4) whose efforts as a peace officer “were a substantial
contributing cause of his death.”2 Id.
The supreme court also stated in a footnote: “If the legislature did not intend this
result, it is free to enact new clarifying legislation. We urge the legislature to clearly define
any future exclusionary language.” Id. at 115 n.3 (emphasis added) (citation omitted).
The statutory history demonstrates that the legislature heeded the supreme court’s
call and enacted “new clarifying legislation” and “exclusionary language” post-Johnson.
The 1980 version of the statute, which Kramer interpreted, included only one exclusion
from the definition of “killed in the line of duty”:
For the purpose of [this statute], killed in the line of duty shall
not include any peace officer who dies as a result of a heart
attack.

Minn. Stat. § 352E.04 (1980). By the time the supreme court decided Kramer, it had
already held that this exclusion was unconstitutional. See Dependents of Ondler v. Peace
Officers Benefit Fund, 289 N.W.2d 486, 490 (Minn. 1980) (holding heart-attack exclusion
violated equal protection). The Kramer court then defined “killed in the line of duty”

2 Even if I were to assume that the limited exception from Johnson controls here— which I
contend it does not—respondent would not qualify for benefits. It is undisputed that his
cause of death was not a heart attack or complications from one. While the majority relies
heavily on the “substantial contributing cause” requirement, this reliance is unpersuasive
because, at a minimum, Deputy Edeburn cannot meet the second and third requirements
from Johnson.

D-6

without relying on statutory language. See Kramer, 380 N.W.2d at 500-01 (looking to
statutory purpose).
The 1985 version of the statute, which Johnson interpreted, provided two new
exclusions:
“Killed in the line of duty” does not include deaths from natural
causes or deaths that occur during employment for a private
employer other than an independent nonprofit firefighting
corporation.

Id. (1985).
As applicable here, the 2024 version 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:
(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

D-7

(3) the presumption is not overcome by competent medical
evidence to the contrary.
(b) “Killed in the line of duty” also means that the officer died
due to suicide:
(1) secondary to a diagnosis of posttraumatic stress disorder as
described in the most recent edition of the Diagnostic and
Statistical Manual of Mental Disorders published by the
American Psychiatric Association; or
(2) within 45 days of the end of exposure, while on duty, to a
traumatic event.

Minn. Stat. § 299A.41, subd. 3 (emphasis added).
The similarities between the current statute and the Johnson-era statute start and end
with the first clause of the first sentence, italicized above. Significantly, after Johnson, the
legislature defined “deaths from natural causes” by creating exceptions to it. These
exceptions include the presumption that a death from a heart attack, stroke, or vascular
rupture constitutes being “killed in the line of duty,” but only if certain requirements are
met.
We recognized this statutory history in Lannon. There, this court concluded 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 in Minn.
Stat. § 299A.41, subd. 3.” 984 N.W.2d at 585 (emphasis added).
3 After Kramer and

3 This court came to the same conclusion in In re Jones, No. A25-0443, 2025 WL 2752621,
at *4-5 (Minn. App. Sept. 29, 2025), rev. granted (Minn. Dec. 17, 2025). There, this court
considered whether death benefits could be awarded to the surviving spouse of a firefighter
who died from a heart attack six years after his retirement. Id. at *1. After noting that
Jones’ death certificate stated that he died from natural causes and not within 24 hours of
strenuous duty-related activities, we concluded that he did not sustain a heart attack in the
line of duty and that the natural-causes exception in the statute rendered his surviving
spouse ineligible for death benefits. Id. at *3, *5. This court also relied on Lannon to reject

D-8

Johnson, the legislature specifically added exceptions to the natural -death exclusion. See
id. This court therefore concluded that “[t]he legislature’s subsequent enactment of Minn.
Stat. § 299A.41, subd. 3, and revisions to that provision, clarified the exclusion of deaths
from natural causes.” Id. In other words, the statute now defines “killed in the line of
duty” by what is included and excluded. This was crucial to Lannon because it allowed
this court to go beyond the 2022 statute’s language, which neither included nor excluded
deaths by suicide, and instead look to the definition established in Kramer and Johnson.
See id. at 585-87. We then held that “an officer’s death by suicide may fit the supreme
court’s definition of the phrase ‘killed in the line of duty’” established in those cases. Id.
at 587. After Lannon, as discussed, the legislature amended the statutory language to also
include certain deaths by suicide. See 2023 Minn. Laws ch. 52, art. 5, § 14, at 877-78.
Respondent’s approach assumes that the statute that exists today is the same one
that Johnson interpreted. That is not true. Respondent ignores the substantial changes to
the statute. By focusing primarily on the first phrase and third line, respondent’s
interpretation also violates the whole-statute canon, which requires courts to give effect to
all the provisions of a statute. See Minn. Stat. § 645.16. I therefore conclude that the
definition and exclusion from Kramer and Johnson do not apply to this case.

the argument that the definition from Kramer and Johnson controls because “[b]oth cases
were issued prior to the amendments refining the natural-causes exclusion.” Id. at *5
(citing 2016 Minn. Laws ch. 189, art. 14, § 3, at 1100). We noted that, after Johnson, the
legislature refined the natural-cause exception and, “as we recognized in Lan non, that
natural-causes exclusion controls.” Id. (citing Lannon, 984 N.W.2d at 585).

D-9

II. The ALJ erred by granting summary disposition to respondent because it
misinterpreted and misapplied Minn. Stat. § 299A.41, subd. 3.

The department argues that Deputy Edeburn’s death by natural causes does not
qualify for death benefits because (1) his death was explicitly excluded from the definition
of “killed in the line of duty” under the plain language of section 299A.41, subdivision 3;
(2) a natural death by active lymphocytic myocarditis is not the same as death by a heart
attack, stroke, or vascular rupture and therefore those exceptions and any presumptions do
not apply; and (3) even if Deputy Edeburn’s death fell into the exception for heart attacks,
strokes, and vascular ruptures —which it does not —he does not meet the statutory
requirements to qualify for benefits. I agree.
A. Deputy Edeburn’s death was explicitly excluded from the definition of
“killed in the line of duty.”

The first part of the statute states: “‘Killed in the line of duty’ does not include
deaths from natural causes, except as provided in this subdivision.” Minn. Stat. § 299A.41,
subd. 3(a) (emphasis added). The plain and unambiguous language of that sentence could
not be clearer: the phrase “killed in the line of duty” does not include deaths from natural
causes, with some exceptions.
The department asserts that the ALJ erred by determining that Deputy Edeburn’s
cause of death was not expressly included or excluded by the plain language of Minn. Stat.
§ 299A.41, subd. 3. I conclude that the ALJ erred in its interpretation because the plain
language of the statute is clear that “death from natural causes” is “not include[d]” as part
of the definition of “killed in the line of duty,” unless an exception applies.

D-10

The undisputed record shows that Deputy Edeburn died from “natural causes,” with
the immediate cause of death being “active lymphocytic myocarditis.” The medical
examiner’s report lists Deputy Edeburn’s immediate cause of death to be from “natural
disease,” and lists the specific cause as “active lymphocytic myocarditis.” Deputy
Edeburn’s death certificate lists the manner of death as “natural.” See Lannon, 984
N.W.2d. at 579 (citing death certificate for “contributing conditions” to decedent’s death).4
In addition, respondent’s expert, Dr. Mason D. Harrell III, reviewed Deputy Edeburn’s
medical records and did not dispute that he died of natural causes or active lymphocytic
myocarditis. I therefore conclude that the plain language of the statute excludes Deputy
Edeburn’s natural-cause death from the definition of “killed in the line of duty,” unless an
exception applies.
B. “Active lymphocytic myocarditis” is not a heart attack, stroke, or
vascular rupture.

The plain language of the statute states that a death from natural causes is excluded
from the definition of killed in the line of duty “except as provided within this subdivision.”
Minn. Stat. § 299A.41, subd. 3(a) (emphasis added). In other words, the statute’s plain
language creates an exception to the natural-causes exclusion for deaths that are “the direct
and proximate result of a heart attack, stroke, or vascular rupture,” subject to certain other
requirements. Id.

4 In Jones, 2025 WL 2752621, at *1, *3, this court noted that “Jones’s death certificate
provides that he died of natural causes” and that “[t]he medical examiner concluded that
the immediate cause of death was probable myocardial infarction (heart attack).” While
Jones is nonprecedential and is cited for its persuasive value only, see Minn. R. Civ. App.
P. 136.01, subd. 1(c), it is strikingly similar to the case at hand.

D-11

This exception becomes a presumption5 of being killed in the line of duty, but only
if certain requirements are met. See id. But myocarditis is a different and distinct cause of
death from a heart attack, much less a stroke or a vascular rupture. Myocarditis is the
inflammation of the heart’s muscular walls, often caused by a viral infection or an
autoimmune disease. In contrast, a heart attack, also known as a myocardial infarction, is
the death of heart tissue caused by a blockage of blood flow to the heart, typically from a
build-up of plaque in the arteries. See The American Heritage Dictionary of the English
Language 811 (5th ed. 2018) (defining “heart attack” as a “[s]udden interruption or
insufficiency of the supply of blood to the heart”).
Here, the undisputed cause of death was active lymphocytic myocarditis. There is
no mention whatsoever of a heart attack or myocardial infarction in the medical examiner’s
report or the death certificate. Indeed, even the report from respondent’s expert,
Dr. Harrell, does not include the words “heart attack” or “myocardial infarction.” Death
from active lymphocytic myocarditis is not death “as the direct and proximate result of a
heart attack, stroke, or vascular rupture.” See Minn. Stat. § 299A.41, subd. 3(a).
Because Deputy Edeburn’s death from natural causes is excluded by the plain and
unambiguous language of Minn. Stat. § 299A.41, subd. 3, and it does not meet the natural-
causes exception of a death by a heart attack, stroke, or vascular rupture, he was not “killed
in the line of duty” and does not qualify for death benefits.

5 In its motion for summary disposition before the ALJ, respondent argued without
supporting authority that the decisionmaker must first determine whether the presumption
under subdivision 3 applies. The ALJ correctly dismissed this argument as inconsistent
with Lannon.

D-12

C. Deputy Edeburn cannot meet the statutory work-related requirements.

Even if Deputy Edeburn’s death had been the direct and proximate result of a heart
attack—which, again, it was not—he does not meet the remaining requirements of the
natural-causes exception.
Continuing the analysis of the whole statutory provision, the natural-causes
exception creates a rebuttable presumption that the person was killed in the line of duty,
but only if: (1) “that officer, while on duty” engaged in “nonroutine stressful or strenuous”
physical activity; (2) “ that officer died as a result of a heart attack, stroke, or vascular
rupture suffered” while engaging in that activity, while still on duty after engaging in that
activity, or “not later than 24 hours after engaging” in that activity; and (3) “the
presumption is not overcome by competent medical evidence to the contrary.” Id., subd.
3(a)(1)-(3).
Deputy Edeburn cannot meet any of these requirements. Viewing the record in the
light most favorable to the department as the nonmoving party, the record reflects that
Deputy Edeburn was on “light duty” at the time of his death. His spouse stated that he
“was cleared for light duty,” and engaged in “desk work,” “observations and
investigations,” and “surveillance.” The record does not support a conclusion that he was
then engaged, nor that had he recently engaged, in any “nonroutine stressful or strenuous
physical” activity or training exercise. Id., subd. 3(a)(1)(i), (ii). As a result, he cannot meet
the requirements to qualify for the presumption of being killed in the line of duty under
section 299A.41, subdivision 3(a)(1)-(2). Further, the record contains competent medical
evidence, including from the medical examiner and Dr. Harrell, that Deputy Edeburn died

D-13

from myocarditis and not one of the exceptions. This evidence would rebut any
presumption under subdivision 3(a)(3).
III. Minn. Stat. § 299A.41, subd. 3, meets the rational- basis test and does not
violate the estate’s equal-protection rights.

Respondent, citing Ondler, 289 N.W.2d at 489, argues that a natural-causes
exclusion would be unconstitutional because it would differentiate based on the manner of
death between officers who die from the same stimuli but at different times. I disagree.
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. Appellate courts review alleged equal-
protection violations de novo. State v. Holloway, 916 N.W.2d 338, 347 (Minn. 2018). 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.”
Id. (quotation omitted). Minnesota’s rational-basis test is more stringent than the federal
test and requires that (1) the challenged distinction “not be manifestly arbitrary or fanciful,”
(2) the challenged distinction “be genuine or relevant to the purpose of the law,” and
(3) “the purpose of the statute must be one that the state can legitimately attempt to
achieve.” Id. at 348 (quotation omitted).

D-14

Respondent’s reliance on Ondler is unpersuasive. There, the supreme court
concluded that a prior version of the death-benefits statute, which categorically excluded
death-benefit coverage for all deaths based on heart attacks, was unconstitutional because
no rational basis existed to distinguish between officers who were killed by heart attacks
and those who we re killed in any other way. 289 N.W.2d at 488-90. That same
constitutional infirmity does not exist in the current version of the statute.
The current death-benefits statute excludes deaths from natural causes but provides
exceptions to that exclusion, allowing compensation for certain types of deaths if relevant
conditions are met. In essence, there must be a close causal connection between the death
and stressful, nonroutine work. 6 This furthers the statute’s purpose to provide benefits to
public safety officers. Moreover, since the Ondler decision in 1980, the statute has been
amended several times to provide broader coverage, including adding exceptions to the
natural-deaths exclusion for deaths by heart attacks, strokes, and vascular ruptures, as well
as accidents. Those changes to the statute are not “arbitrary or fanciful,” but rather

6 Kramer and Johnson required a similar causal connection, though both cases focused on
heart attacks. See Kramer, 380 N.W.2d at 502 (requiring that heart-attack death relate to
“a duty peculiar to” employment); Johnson, 431 N.W.2d at 111 (syllabus) (requiring that
heart attack be “suffered while engaged in the hazards” of being a peace officer) ; id.
(excepting heart-attack deaths from natural-causes exclusion if “[peace-officer] efforts
were a substantial contributing cause”). To the extent that respondent argues the statute
violates equal protection because of its causal requirement, Johnson and Kramer would
also violate equal protection for that same reason.

D-15

“genuine” and “relevant” to further the purpose of the law to provide coverage. 7 See
Holloway, 916 N.W.2d at 348 (quotation omitted).
Deputy Edeburn’s public service was certainly commendable. I agree with the
majority that the legislature has revised the death-benefits statute numerous times to
carefully and thoughtfully expand coverage. But it is not the role of this court to expand
those exceptions beyond the plain language of the statute. Instead, we are required to
follow the plain language of the statute if it is clear and unambiguous. The exclusion for
deaths by natural causes from the definition of “killed in the line of duty” in Minn. Stat.
§ 299A.41, subd. 3, is plain and unambiguous. It is undisputed that Deputy Edeburn died
of natural causes, so he falls within that exclusion, and he did not die of a heart attack,
stroke, or vascular rupture, so he does not meet that exception or qualify for a presumption
that he was nevertheless killed in the line of duty. It is also undisputed that Deputy Edeburn
did not engage in nonroutine strenuous or stressful physical law -enforcement activities in
the 24 hours preceding his death. As a result, I would conclude that the ALJ erred in its
interpretation of Minn. Stat. § 299A.41, and I would reverse and remand.

7 This court in Jones rejected the same argument. See 2025 WL 2752621, at *6. There,
we distinguished Ondler because it involved uncontradicted evidence that the firefighter
had died while fighting a fire and a causal connection existed between the death and the
stress from fighting the fire. Id. On the merits, we held that a rational basis existed for the
distinction because “there is a close connection between unusual work-imposed stress and
a heart attack suffered in close temporal relation to that work-imposed stress.” Id.