Jamie John Wojcik v. Michael John Wilson, et al
Opinion text
This opinion is nonprecedential except as provided by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
A25-1662
Jamie John Wojcik, petitioner,
Appellant,
vs.
Michael John Wilson, et al.,
Respondents.
Filed September 14, 2026
Affirmed
Rasmusson, Judge
Isanti County District Court
File Nos. 30-FA-24-130, 30-FA-23-330
Jamie John Wojcik, Ogilvie, Minnesota (pro se appellant)
George Herbert Hanson, Hanson Law Office, PLLC, Hallock, Minnesota (for respondents)
Considered and decided by Rasmusson, Presiding Judge; Bratvold, Judge; and
Slieter, Judge.
∗
NONPRECEDENTIAL OPINION
RASMUSSON, Judge
In this appeal from a grant of third- party custody to respondents, appellant argues
that the district court abused its discretion by (1) failing to recognize him as the father of
the child prior to legal adjudication of paternity, (2) awarding sole physical and legal
∗ Retired judge of the Minnesota Court of Appeals, serving by appointment pursuant to
Minn. Const. art. VI, § 10.
2
custody to respondents, and (3) violating his due-process and equal-protection rights. We
affirm.
FACTS
Appellant Jamie John Wojcik had a romantic relationship with Lily Wilson, who is
now deceased. During their relationship, Lily gave birth to a child, L.E.W., whom she
raised with Wojcik for about seven years until their romantic relationship ended in 2021.
Lily and L.E.W. lived with Lily’s parents, respondents Michael and Patricia Wilson, from
2021 until Lily’s death in 2023. Prior to Lily’s death, Wojcik saw L.E.W. approximately
once a month.
After Lily died, the Wilsons petitioned the district court for emergency third -party
custody of L.E.W. , citing concerns that Wojcik, the putative father, 1 was a danger to
L.E.W. because of substance use, mental-health issues, and his threats to remove L.E.W.
from the state. The district court granted the Wilsons temporary legal and physical custody
of L.E.W. and ordered Wojcik to “immediately submit to a 5-panel hair follicle test.”
Wojcik responded with an affidavit, denying the allegations and requesting
immediate custody of L.E.W. At a hearing, the district court repeatedly explained to
Wojcik that he did not have legal status as L.E.W.’s parent and that the district court had
no power to grant him his request until he established legal parentage. The district court
subsequently ordered Wojcik to submit to a drug test within 72 hours.
1 A “putative father” is a man who may be a child’s father but was not married to the child’s
mother on or before the child’s birthdate and has not established legal paternity of the child.
Minn. Stat. § 259.21, subd. 12 (2024).
3
Between January and April 2024, Wojcik filed two legally invalid birth certificates;
an ineffective recognition-of-parentage (ROP) form; numerous filings and “emergency”
motions; and, eventually, a negative drug test issued by a facility different from the one the
district court ordered him to use. In an order filed on April 10, 2024, the district court
stated that until paternity was adjudicated, it could not recognize Wojcik as L.E.W.’s legal
father, but in two footnotes laid out the statutory framework under which Wojcik could file
a paternity action. It stated that if no paternity action had been initiated within 90 days, the
Wilsons could move for permanent custody.
Wojcik filed a paternity action on April 24, 2024. The district court then ordered
genetic testing and based upon the results, adjudicated Wojcik the legal father of L.E.W.
It also ordered the paternity and third- party-custody cases to be merged and appointed a
guardian ad litem (GAL). The GAL report was filed in May 2025 and included a custodial
recommendation for the Wilsons and cited information from a psychological evaluation
which included multiple mental-health diagnoses for Wojcik.
In the summer of 2025, the district court held a six-day trial, hearing testimony from
multiple witnesses, including the GAL and L.E.W.’s therapist. After the trial, the district
court awarded the Wilsons permanent sole legal and physical custody. It also set a
multi-phase parenting-time schedule in which Wojcik could transition from supervised to
unsupervised parenting time as he and L.E.W. progress through reunification therapy, so
long as Wojcik engages in individual therapy and submits proof of negative drug tests. The
district court also provided an alternative schedule in which Wojcik’s parents would be
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entitled to visitation with L.E.W. if Wojcik is convicted and incarcerated in a pending
criminal case.
Wojcik appeals.
DECISION
Wojcik argues that the district court abused its discretion by (1) failing to recognize
him as L.E.W.’s father prior to formal adjudication of paternity, (2) awarding permanent
sole legal and physical custody to the Wilsons, and (3) violating his due-process and
equal-protection rights.2
District courts have broad discretion to determine matters of custody. Durkin v.
Hinich, 442 N.W.2d 148, 151 (Minn. 1989). Appellate courts review custody
determinations for an abuse of discretion. Lewis-Miller v. Ross, 710 N.W.2d 565, 568
(Minn. 2006). A district court abuses its discretion if its findings of fact are unsupported
by the record, if it improperly applies the law, or if it resolves an issue contrary to logic
and the facts on the record. Woolsey v. Woolsey, 975 N.W.2d 502, 506 (Minn. 2022).
“Whether the district court correctly applied the law is a legal question, which we review
de novo.” In re Welfare of Child. of M.A.H., 839 N.W.2d 730, 746 (Minn. App. 2013).
2 Wojcik also argues that we should vacate the temporary ex parte order granting temporary
custody to the Wilsons. Even if we concluded that the district court abused its discretion
by issuing the temporary order, it is unclear what relief we could provide because the
temporary order no longer has any legal effect now that the district court has made a
permanent custody determination. See, e.g., Sharp v. Bilbro, 614 N.W.2d 260, 262 (Minn.
App. 2000) (declining to address the issue of temporary custody as moot when permanent
custody awarded), rev. denied (Minn. Sep. 26, 2000). The issue of whether the temporary
order was proper is therefore moot, and we focus our attention on the district court’s
determination of permanent custody.
5
I. The district court did not abuse its discretion by failing to recognize Wojcik as
L.E.W.’s legal father prior to August 2024.
Wojcik argues that the district court abused its discretion by not recognizing him as
L.E.W.’s legal father when it failed to immediately recognize his presumptive parentage
or compel genetic testing between December 2023 and April 2024. We are not persuaded.
We first evaluate Wojcik’s argument that the district court failed to recognize his
presumptive parentage. The legal framework for establishing paternity and a parent-child
relationship is found in the Minnesota Parentage Act (MPA). Minn. Stat. §§ 257.51-.75
(2024); Morey v. Peppin, 375 N.W.2d 19, 22 (Minn. 1985) (stating the MPA “governs the
establishment of the parent and child relationship”). A “‘parent and child relationship’
means the legal relationship existing between a child and the child’s biological or adoptive
parents.” Minn. Stat. § 257.52. This established legal relationship is the mechanism by
which the law “confers or imposes rights, privileges, duties, and obligations.” Id.
The process to establish a parent and child relationship differs for biological mothers
and biological fathers. “The parent and child relationship between a child and . . . the
biological father may be established under [the MPA]” by executing an ROP, by bringing
a paternity action, or through an adoption. Minn. Stat. § 257.54(b). In this case, Wojcik
did not follow any of the statutory processes to establish a parent and child relationship
with L.E.W. Although Wojcik alleged that he was the biological father, he failed to
produce any effective legal document recognizing or adjudicating him L.E.W.’s legal
father. For example, he produced two sovereign-citizen birth certificates, which are not
legal documents in Minnesota, and an ROP that was not effective because it was not signed
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by both parties. See Minn. Stat. § 257.75, subd. 1. And even though the district court
advised Wojcik of the process to establish paternity, Wojcik failed to utilize the system for
months.
Throughout his briefing to this court, Wojcik emphasizes that he had previously
lived with Lily and L.E.W. and had acted as a father to L.E.W. for many years, but those
assertions are insufficient to establish paternity. A man who receives a minor child “into
his home and openly holds out the child as his biological child” is presumed to be the
biological father. Minn. Stat. § 257.55, subd. 1(d). A presumed father under section
275.55, subdivision 1(d), may bring a paternity action at any time for the purpose of legally
establishing the father-and-child relationship. Minn. Stat. § 257.57, subd. 2(1). However,
the presumption is not applicable until a paternity action commences. In re J.M.M., 937
N.W.2d 743, 750 n.6 (Minn. 2020) (evaluating when a biological father may obtain custody
and other legal rights under the MPA).
3
Wojcik filed the paternity action in April 2024, and he was adjudicated L.E.W.’s
father by August 2024. The district court properly applied the parental presumption after
Wojcik filed the paternity action; therefore, it did not abuse its discretion.
3 This applies to cases in the family court division, in which parentage-determination
matters are heard. See Minn. Gen. R. Prac . 301.01(b)(6). A district court acting as a
juvenile court is required to treat presumed fathers as parents in dependency actions,
including giving them the right to notice of proceedings and the right to be assessed and
considered for day-to-day care of the child. Minn. Stat. § 260C.150, subd. 2(a) (2024); see
Minn. Stat. § 484.01, subd. 1(5) (2024) (providing district courts with “jurisdiction of a
juvenile court as provided in chapter 260”); Minn. Stat. § 260.012 (2024) (explaining
juvenile court duties in child-protection matters).
7
We next turn to Wojcik’s claim that the district court failed to order genetic testing
between December 2023 and April 2024.
A man alleging that he is a child’s biological father who wishes to request genetic
testing “shall file with the court an affidavit either alleging or denying paternity and setting
forth facts that establish the reasonable possibility that there was, or was not, the requisite
sexual contact between the parties.” Minn. Stat. § 257.62, subd. 1. Upon receiving this
request, the district court “shall require the child, mother, or alleged father to submit to
blood or genetic tests.” Id. “However, the mere existence of a biological
connection . . . does not confer due process protection on the putative father’s parental
interests.” Heidbreder v. Carton, 645 N.W.2d 355, 372 (Minn. 2002) (citing Lehr v.
Robertson, 463 U.S. 248, 260-61 (1983)).
Wojcik deposited his DNA at a testing establishment and repeatedly demanded that
the Wilsons have L.E.W. tested there. Wojcik did not initiate his paternity action until
April 24, 2024, when he filed a petition (1) alleging the requisite sexual contact between
him and Lily, (2) asking the district court to establish paternity and custody, and
(3) requesting the district court order genetic testing. He also sent a stand-alone motion for
genetic testing to the district court on May 6, 2024. The district court ordered genetic
testing “both on its own initiative and based on [Wojcik’s] request” on May 7, 2024. In
June 2024, the laboratory verified through DNA results that Wojcik is L.E.W.’s biological
father. The district court then adjudicated Wojcik father of L.E.W. and merged the
paternity and third-party-custody files in August 2024.
8
The district court properly applied the law by ordering genetic testing after Wojcik
initiated the paternity action, and adjudicating Wojcik L.E.W.’s father promptly after
genetic-test results indicated that he is L.E.W.’s biological father. Therefore, we conclude
that the district court did not abuse its discretion by not recognizing Wojcik as L.E.W.’s
legal father prior to August 2024.
II. The district court did not abuse its discretion by awarding permanent sole legal
and physical custody of L.E.W. to the Wilsons.
Wojcik next argues that the district court abused its discretion by awarding
permanent sole legal and physical custody of L.E.W. to the Wilsons because it (1) failed
to apply the presumption in favor of a fit parent, (2) improperly relied on the separation
created by the district court to support its custody award, (3) mischaracterized Wojcik’s
filings and improperly relied on them to justify third-party custody, and (4) allowed a
pattern of witness intimidation, thereby suppressing evidence that could have been
supportive of a custody award to Wojcik.
The procedure for petitioning for child custody as an interested third party is
governed by Minnesota Statutes section 257C.03 (2024). Subdivision 7 requires that “[t]o
establish that an individual is an interested third party,” an individual must both “prove by
a preponderance of the evidence that it is in the best interests of the child to be in the
custody of the interested third party” and “show by clear and convincing evidence” one of
the following three factors:
(i) the parent has abandoned, neglected, or otherwise exhibited
disregard for the child’s well-being to the extent that the child
will be harmed by living with the parent;
9
(ii) placement of the child with the individual takes priority
over preserving the day-to-day parent-child relationship
because of the presence of physical or emotional danger to the
child, or both; or
(iii) other extraordinary circumstances[.]
Minn. Stat. § 257C.03, subd. 7(a).
We review a district court’s third-party-custody determination for an abuse of
discretion. Lewis-Miller, 710 N.W.2d at 568. “A district court abuses its discretion by
making findings unsupported by the evidence or by improperly applying the law.” Ramirez
v. Luna (In re Custody of A.L.R.), 830 N.W.2d 163, 166 (Minn. App. 2013) (quotation
omitted).
A. Parental Presumption
Wojcik argues that the district court failed to apply the presumption favoring
custody of a parent and instead evaluated custody by placing him and the Wilsons on equal
footing. He contends that because the district court did not find that he was unfit or had
abandoned L.E.W., this was a practice forbidden by the supreme court in Rodgers v. Knauff
(In re Custody of N.A.K.), 649 N.W.2d 166 (Minn. 2002), and the district court should not
have reached a best-interests analysis.
First, Wojcik misstates the parental presumption. In Rodgers (N.A.K.), the supreme
court held:
[F]ollowing the death of a custodial parent, a surviving,
noncustodial parent is entitled to custody unless the
presumption that the parent be awarded custody is overcome
by extraordinary circumstances of a grave and weighty nature,
indicating that the best interests of the child require that the
surviving parent be denied custody.
10
649 N.W.2d at 175 (emphasis added). This parental presumption is “incorporated into
chapter 257C.” Ramirez (A.L.R.), 830 N.W.2d at 168. Contrary to Wojcik’s assertions,
the district court is not required to find that the parent is unfit or has abandoned the child
to overcome the parental presumption if it finds that “other extraordinary circumstances”
exist and that it is in the best interests of the child to be in the custody of the interested third
party. Minn. Stat. § 257C.03, subd. 7(a)(1) (providing that for an individual to establish
they are an interested third party, they must “show by clear and convincing evidence that
one of [the three] factors exist” (emphasis added)), (a)(2) (providing that an individual must
“prove by a preponderance of the evidence that it is in the best interests of the child to be
in the custody of the interested third party”); see also Rodgers (N.A.K), 649 N.W.2d at 175;
In re Hohmann, 95 N.W.2d 643, 646-47 (Minn. 1959) (holding that a surviving
noncustodial parent’s right to custody could be denied when, “irrespective of [a parent’s]
fitness, exceptional circumstances indicate that the best interests of the child clearly require
that the surviving parent be denied custody”). Extraordinary circumstances are “those of
a grave and weighty nature.” Ramirez (A.L.R.), 830 N.W.2d at 170; see also Rodgers
(N.A.K.), 649 N.W.2d at 175.
The district court’s order demonstrates that it considered the “longstanding
presumption that a [parent] is entitled to the custody of [their] children” when applying
Minn. Stat. § 257C.03, subd. 7, but determined that an award of custody to the Wilsons “is
consistent with other situations where courts have deviated from the parental-custody
presumption.” Specifically, the district court found that the Wilsons had “shown by clear
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and convincing evidence that other extraordinary circumstances exist that warrant[ed] their
intervention as interested third parties and militate[d] in favor of awarding them permanent
custody.” These extraordinary circumstances included Wojcik’s demonstrated “instability
of character,” the substantial concerns raised in the GAL report about how L.E.W.’s mental
health would be impacted should Wojcik be granted full custody, significant concerns
about Wojcik’s mental health, and the number of significant negative life changes
experienced by L.E.W., necessitating stability so that he could thrive.
We conclude that the district court did not abuse its discretion because it applied
Minn. Stat. § 257C.03, subd. 7, in determining that the Wilsons were interested third
parties, and its determination that extraordinary circumstances exist is supported by the
record.
B. Period of Separation
Wojcik contends that the district court improperly relied on the separation it created
in the temporary custody order when it ultimately awarded the Wilsons permanent sole
legal and physical custody.
In addition to establishing their status as an interested third party, the interested third
party must “prove by a preponderance of the evidence that it is in the best interests of the
child to be in [their] custody.” Minn. Stat. § 257C.03, subd. 7(a)(2). The statute provides
a list of factors that a district court must consider in assessing the interested-third-party’s
petition. See Minn. Stat. §§ 257C.03, subd. 7(b), .04, subd. 1 (2024).
Two of the factors that the district court must consider include (1) “the length of
time the child has lived in a stable, satisfactory environment and the desirability of
12
maintaining continuity” and (2) “the permanence, as a family unit, of the existing or
proposed custodial home.” Minn. Stat. § 257C.04, subd. 1(a)(7)-(8). Therefore, the district
court is required to consider both the length of time a child has resided in an environment
and the permanence of each proposed custodial home.
The district court’s order demonstrates that it considered the necessary factors. The
district court found that L.E.W. had lived with the Wilsons beginning in 2021, when Lily
and Wojcik terminated their romantic relationship. It also stated that by the time it was
able to adjudicate Wojcik father, L.E.W. had been living with the Wilsons for eight months
after Lily’s death pursuant to the earlier award of temporary custody. However, because
“the guiding principle in child-custody matters is to satisfy the best interests of the child,”
the district court determined that L.E.W. should not be moved during the pendency of the
custody case because it was “unclear whether Wojcik would ultimately be determined to
be the appropriate custodian.”
Wojcik attributes his separation from L.E.W. to the district court; however, it was
Wojcik’s choices that impacted his contact with L.E.W. Wojcik chose not to pursue
paternity during the nine years prior to Lily’s death, and he was reluctant to file an action
to adjudicate his paternity until the district court established a deadline and awarded
temporary custody to the Wilsons.
Ultimately, the district court determined that these factors favored the Wilsons, but
it did not base its decision on them predominantly. Instead, the district court found that the
factor regarding intimacy between the parent and child was neutral, noting that Wojcik’s
opportunities to develop intimacy with L.E.W. in recent years have been fewer, partly due
13
to a court order. See Minn. Stat. § 257C.04, subd. 1(a)(4). The district court weighed all
of the statutory factors, including the ones discussed here, when coming to its decision and
did not hold any court-ordered separation against Wojcik.
We conclude that the district court did not abuse its discretion in considering these
two factors because it weighed them fairly and in conjunction with the other statutorily
required factors.
C. Consideration of Wojcik’s Filings
Wojcik next contends that the district court mischaracterized his filings and
improperly relied on them to justify third-party custody because it summarily denied many
of his motions and described some of his filings as “spurious.”
A district court abuses its discretion by focusing on conduct asserted to support a
claim, and not on the claim itself. See Meadowbrook, Inc. v. Tower Ins. Co., 559 N.W.2d
411, 420 (Minn. 1997) (“In this case, the court of appeals mistakenly focused on some of
the conduct being asserted to prove the claim.”).
Here, the record is replete with numerous filings from Wojcik, with many of them
nearly exact duplicates of earlier filings. Wojcik did not wait for the district court to
respond but repeatedly filed the same information in varying formats. These filings
continued throughout the pendency of the case, even after the district court ordered Wojcik
to follow court rules. After a six-day trial, where Wojcik called and cross-examined
witnesses and made arguments in his favor, he filed 36 motions or affidavits repeating his
argument during the time the district court had the matter under advisement.
14
The volume of repeated filings goes far beyond the exercise of rights or conduct
necessary to support his claims. The district court found that “Wojcik’s penchant for filing
numerous duplicative and spurious motions throughout the pendency of this case
demonstrates an inability or unwillingness to follow the court’s rules,” which it determined
was one of many examples consistent with his mental-health diagnoses. The district court
also noted his noncompliance with court orders, which is supported by the record.
We conclude that the district court did not abuse its discretion because the record
supports its determination that the filings demonstrate Wojcik’s unwillingness to follow
court rules. Furthermore, the district court’s order demonstrates that it considered the
merits of Wojcik’s arguments in making its determinations, rather than relying on the
timing or volume of Wojcik’s pleadings.
D. Witness Intimidation
Wojcik contends that the district court abused its discretion by depriving him of a
fair trial because it did not address “a documented pattern of witness intimidation, threats,
and coercion.” Most of Wojcik’s references to improper coercion or intimidation relate to
nonparties in the case or are citations to witness testimony that the district court, as
fact-finder, weighed in making its determinations. However, during trial, Wojcik reported
that he received “death threats” from a friend of Lily’s. The district court allowed a recess
so that Wojcik could report the threats to police and then, even though the misconduct was
just an allegation, excluded the person from the courtroom in the interest of “fairness and
making sure that [Wojcik] feels safe.” The district court did not fail to address allegations
15
of witness intimidation, threats, or coercion. Instead, it took appropriate action and made
findings regarding any wrongdoing by the parties.
We conclude that the district court did not abuse its discretion because it did not
mishandle reports of witness threats and coercion.
III. The district court did not deprive Wojcik of due process or equal protection.
Throughout his brief, Wojcik claims that the district court deprived him of due
process.
Appellate courts review this issue de novo. Sawh v. City of Lino Lakes, 823 N.W.2d
627, 632 (Minn. 2012). “We conduct a two-step analysis to determine whether the
government has violated an individual’s procedural due process rights.” Id.
First, appellate courts identify whether the person was deprived of a “protected life,
liberty, or property interest.” Id. After a district court adjudicates a presumed father as the
legal father, the court order declaring “the existence . . . of the parent and child relationship
is determinative.” Minn. Stat. § 257.66, subd. 1. “A determination that a father-and-child
relationship exists carries with it significant, fundamental parental rights . . . .” In re
Welfare of Child of S.B.G., 991 N.W.2d 874, 882 (Minn. 2023). Although Wojcik claims
that he was deprived of his constitutional rights from the beginning of the
third-party-custody action, his fundamental parental rights did not attach until he was
adjudicated L.E.W.’s legal father.
Under the second step, we must determine whether the district court employed
constitutionally sufficient procedures. Sawh , 823 N.W.2d at 632. Constitutionally
sufficient procedures include notice and an opportunity to be heard. Id. To decide whether
16
a procedure meets this standard, appellate courts would typically apply the factors from
Mathews v. Eldridge, 424 U.S. 319 (1976). 4 But Wojcik does not analyze the Mathews
factors. Instead, he equates receiving due process with immediately prevailing in court.
As the district court observed, Wojcik’s position throughout the trial “[was] that, because
he is L.E.W.’s biological father, he has a presumption of custody—and it was therefore a
violation of his rights for the [district court] to do anything other than grant him immediate
custody.”
Wojcik also argues that he was denied due process because the district court
dismissed some of his motions without a hearing. But “[d]ue process does not always
require a full evidentiary hearing.” State v. LeDoux, 770 N.W.2d 504, 514 (Minn. 2009).
Throughout his briefing, Wojcik repeatedly argues that his constitutional rights were
violated under Stanley v. Illinois, 405 U.S. 645 (1972). Stanley is a case that involves the
removal of children by a child-welfare agency from a man who was legally the children’s
father with no opportunity for the father to demonstrate his fitness. Therefore, it is unlike
this case where Wojcik began as a putative father and then, after he was adjudicated the
4 The Mathews factors require us to consider:
First, the private interest that will be affected by the official
action; second, the risk of an erroneous deprivation of such
interest through the procedures used, and the probable value, if
any, of additional or substitute procedural safeguards; and
finally, the Government’s interest, including the function
involved and the fiscal and administrative burdens that the
additional or substitute procedural requirement would entail.
424 U.S. at 335.
17
legal father, he was given an opportunity to be heard regarding his request for custody of
his child. We conclude that Wojcik had notice and a meaningful opportunity to be heard
when he thoroughly participated in the six-day trial.
Lastly, Wojcik alleges that the district court abused its discretion by depriving him
of equal protection in violation of the Fourteenth Amendment when it ordered him to
participate in monthly hair-follicle tests, mental-health therapy, reunification therapy, and
supervised parenting time, but did not order any conditions upon Patricia Wilson, despite
witness testimony alleging that she uses controlled substances and struggles with alcohol
use.
The Equal Protection Clause requires that similarly situated individuals receive
equal treatment. State v. Frazier, 649 N.W.2d 828, 837 (Minn. 2002). Equal-protection
claims are usually asserted in the context of challenging statutory classifications. See, e.g.,
State v. Merrill, 450 N.W.2d 318, 321 (Minn. 1990). Wojcik does not challenge a statute,
nor does he cite any standard that the district court applied unequally to the parties. The
initial question in equal-protection claims is whether “the claimant is similarly situated in
all relevant respects to others whom the claimant contends are being treated differently.”
Schroeder v. Simon, 985 N.W.2d 529, 549 (Minn. 2023) (quotation omitted).
Equal-protection claims are “routinely rejected” when a party cannot make the threshold
showing that they are “similarly situated to those whom they contend are being treated
differently.” State v. Cox, 798 N.W.2d 517, 521 (Minn. 2011).
We understand Wojick’s argument to be that he is similarly situated to Patricia
Wilson. Wojick does not cite to any relevant authority in support of his position. See
18
Brodsky v. Brodsky, 733 N.W.2d 471, 479 (Minn. App. 2007) (declining to consider an
inadequately briefed issue). Because Wojick has failed to establish that he is similarly
situated in all relevant respects to Patricia Wilson, his equal-protection claim fails. See
Doll v. Barnell, 693 N.W.2d 455, 462 (Minn. App. 2005) (failing to make the threshold
showing that the parties are similarly situated disposes of equal-protection claim).
We conclude that because the district court did not deny Wojcik due process or
equal protection, it did not abuse its discretion.
Affirmed.