Alexander Nelson, Appellant,

This opinion is nonprecedential except as provided by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
A25-1940

Alexander Nelson,
Appellant,

vs.

Arroyo Insurance Services, Inc.,
Respondent.

Filed June 8, 2026
Affirmed
Reyes, Judge

Hennepin County District Court
File No. 27-CV-25-1525

Alexander Nelson, Minneapolis, Minnesota (self-represented appellant)

Arroyo Insurance Services, Inc., Pasadena, California (respondent)

Considered and decided by Bond, Presiding Judge; Reyes, Judge; and Harris, Judge.
NONPRECEDENTIAL OPINION
REYES, Judge
Appellant challenges the district court’s second denial of his fee-waiver application,
arguing that its frivolous-action determination is (1) barred by collateral estoppel and (2) an
abuse of the district court’s discretion. We affirm.

2
FACTS
In January 2025, appellant Alexander Nelson 1 filed a complaint in district court
asserting that respondent Arroyo Insurance Services, Inc., violated his rights under the
Minnesota Human Rights Act, Minn. Stat. §§ 363A.01-.50 (2024) (MHRA), and a
Minneapolis city ordinance. In his complaint, Nelson contended that he sought specialty
textile insurance from Arroyo, and Arroyo’s policies required a potential insured party to
be a homeowner. Nelson requested that Arroyo waive this homeowner requirement as a
“reasonable accommodation” because his disability “forced [him] to rent his home at a
disability apartment complex.” Arroyo refused, suggesting instead that Nelson “just look
for another insurance company to solve the problem.” Nelson asserted that Arroyo’s
refusal to insure him constituted discrimination based on his status as a “disabled person”
under the MHRA and Minneapolis ordinance.
On the same day that he filed the complaint, Nelson applied to the district court for
a fee waiver to proceed with his claim. The district court denied the fee-waiver request in
a form order, checking a box that stated: “The action is frivolous.” Nelson appealed the
fee-waiver denial.
In June 2025, this court filed a precedential opinion on that appeal concluding that,
when denying a fee-waiver request, “a district court need not make extensive findings, but

1 We note that it is unclear whether this is appellant’s legal name, as he concedes to having
litigated at least five separate cases under the name “Aaron Olson.” The caption of this
opinion conforms to the caption used in the district court. See Minn. R. Civ. App. P.
143.01. We use the name Nelson, as stated in appellant’s briefing, throughout the body of
this opinion.
3
it should set forth a reason for its decision to enable meaningful appellate review.” Nelson
v. Arroyo Ins. Servs., Inc., 23 N.W.3d 415, 419 (Minn. App. 2025). Because the district
court made no findings, and we could not discern the reason for the denial from the record,
we remanded for the district court to support its determination that the action was frivolous.
Id.
In August 2025, Nelson filed another fee-waiver request with the district court,
which it denied in October 2025. In a three-page order explaining its determination that
Nelson’s action was frivolous, the district court referenced a September 2025 order in a
separate case, in which it had designated Nelson a “frivolous litigant” and imposed certain
sanctions on him.
This appeal follows.2
DECISION
Nelson challenges the district court’s second fee-waiver denial, arguing that its
frivolous-action determination is (1) barred by collateral estoppel and (2) an abuse of
discretion. We address each argument in turn.
I. Nelson failed to adequately brief his collateral-estoppel argument.

Nelson first contends that the district court could not make a frivolous-action
determination because this court “has already reviewed” his complaint and concluded “that
it could not see frivolity.” We disagree.

2 Arroyo did not file a brief in this court. This court ordered the appeal to proceed pursuant
to Minn. R. Civ. App. P. 142.03, which provides that, if the respondent does not file and
serve a brief, “the case shall be determined on the merits.”
4
Appellate courts review de novo “[w]hether collateral estoppel precludes litigation
of an issue.” Hauschildt v. Beckingham, 686 N.W.2d 829, 837 (Minn. 2004). Collateral
estoppel, also known as issue preclusion, “prevents parties from relitigating issues
determined in a prior action.” In re Est. of Perrin, 796 N.W.2d 175, 179 (Minn. App. 2011)
(emphasis added), rev. denied (Minn. June 28, 2011).
Nelson appears to direct this argument to the district court’s ability to consider
whether his action is frivolous on remand. He does not make a legal argument or cite to
any caselaw to support the proposition that a district court may be collaterally estopped
from determining an issue that we properly remanded to it. This issue is therefore
inadequately briefed, and we need not consider it.3 See In re Civ. Commitment of Kropp,
895 N.W.2d 647, 653 (Minn. App. 2017), rev. denied (Minn. June 20, 2017).
II. The district court did not abuse its discretion by making a frivolous-action
determination and then denying Nelson’s fee-waiver request.

Nelson next argues that the district court abused its discretion when it determined
that his action is frivolous because it “base[d]” this determination on (1) a separate
September 2025 order; (2) his frivolous filings in other cases, without citing to them; and
(3) only part of his requested relief. We are not persuaded.

3 Even if we considered Nelson’s argument, it fails on at least one prong of the collateral-
estoppel analysis: We did not enter “a final judgment on the merits.” Mach v. Wells
Concrete Prods. Co., 866 N.W.2d 921, 927 (Minn. 2015). In Nelson, this court addressed
whether the district court’s first fee-waiver denial enabled “meaningful appellate review.”
23 N.W.3d at 419 . We remanded, specifically noting: “[W]e express no opinion on
whether Nelson’s claims are frivolous . . . .” Id. at 419 n.5. On remand, the district court
determined that Nelson’s action is indeed frivolous.
5
A district court “shall allow” a civil action to proceed “without payment of fees,
costs, and security for costs” if the action “is not of a frivolous nature” and the applicant is
financially unable to pay litigation costs. Minn. Stat. § 563.01, subd. 3(a)-(b) (2024). This
appeal centers on only the frivolousness prong of this statute.
We review the district court’s denial of a fee-waiver application for an abuse of
discretion. Nelson, 23 N.W.3d at 418. A district court abuses its discretion if its factual
findings are unsupported by the record, if it improperly applies the law, or if it resolves a
question in a manner that is contrary to logic and the facts on record. Woolsey v. Woolsey,
975 N.W.2d 502, 506 (Minn. 2022). “[W]e cannot assume error by the district court on
appeal.” Butler v. Jakes, 977 N.W.2d 867, 873 (Minn. App. 2022). The challenging party
“bears the burden of proving that the district court abused its discretion.” Blehr v.
Anderson, 955 N.W.2d 613, 624 (Minn. App. 2021); see, e.g., Cloutier v. Cloutier, 112
N.W.2d 347, 353 (Minn. 1961) (affirming district court when appellant could not show it
abused its discretion).
A. The district court did not abuse its discretion by referencing the separate
September 2025 order.

We are not persuaded by Nelson’s argument that the district court relied on a
September 2025 order when making its frivolous-action determination.
Nelson commenced the action underlying this appeal in January 2025, and we filed
our remand decision in June 2025. A September 2025 order in a separate case designated
Nelson a “frivolous litigant” and set out certain terms for him to follow for “any new filings
submitted in Hennepin County District Court.”
6
In October 2025, the district court denied Nelson’s fee-waiver request in this case.
That denial referenced the September 2025 order and summarized the sanctions that it had
imposed on Nelson.
Nelson points to no errors of law, misapplication of the facts, or illogical reasoning
by the district court referencing the September 2025 order in its fee-waiver denial. Because
we do not assume error by the district court, we conclude that the district court did not
abuse its discretion by referencing the September 2025 order. See Butler, 977 N.W.2d at
873.
B. The district court did not abuse its discretion by discussing Nelson’s
separate frivolous filings.

We are not persuaded by Nelson’s argument that the district court needed to cite to
cases that Nelson “is attempting to relitigate with this instant case.”
The district court explained that Nelson “has displayed a pattern of frivolous filings
against various entities,” and determined that the action underlying this appeal “is similarly
baseless.”
At no point did the district court determine that Nelson is attempting to relitigate
another case here. The basis of Nelson’s assertion is therefore unclear. Nelson provides
no legal argument and cites to no caselaw to support this assertion, and we decline to
consider issues that are inadequately briefed. Kropp, 895 N.W.2d at 653; see also
Fitzgerald v. Fitzgerald, 629 N.W.2d 115, 119 (Minn. App. 2001) (“Although some
accommodations may be made for [self-represented] litigants, this court has repeatedly
7
emphasized that [self-represented] litigants are generally held to the same standards as
attorneys and must comply with court rules.”).
Relatedly, Nelson’s argument reflects a misunderstanding of the law. The term
“frivolous action” appears in the context of fee-waiver requests, like the fee-waiver request
underlying this appeal. See Minn. Stat. § 563.01, subd. 3(b). The term “frivolous litigant,”
by contrast, appears in the context of a motion for security or sanctions, like that discussed
in the September 2025 order. See Minn. Gen. R. Prac. 9.01. One of three definitions of
“frivolous litigant,” listed in Minnesota General Rule of Practice 9.06, describes someone
who “repeatedly relitigates or attempts to relitigate” a claim that has been finally
determined against them. Nelson appears to conflate this definition of a frivolous litigant
with the district court’s determination that Nelson’s complaint involves a frivolous action.
Although we have not defined the exact bounds of what constitutes a “frivolous
action,” we are not persuaded that a district court must find that someone is a “frivolous
litigant” before it can determine that an action is frivolous. We conclude that the district
court did not need to cite to cases that Nelson is attempting to relitigate to support its
frivolous-action determination.
C. The district court did not abuse its discretion by restating part of
Nelson’s requested relief.

We are also not persuaded by Nelson’s argument that the district court based its
frivolous-action determination on the fact that Nelson requested physical-injury damages.
8
At the end of its order, the district court restated verbatim one sentence from
Nelson’s complaint that focused on requested relief for physical-injury damages. It did not
mention the other relief that Nelson requested.
Nelson’s argument is unpersuasive for two reasons. First, at no point did the district
court determine that Nelson requested relief only in the form of physical-injury damages.
Instead, it accurately noted that Nelson’s complaint included a request for physical-injury
damages. Second, Nelson provides no legal argument and cites to no relevant caselaw to
support the assertion that a district court abuses its discretion by discussing part, but not
all, of a plaintiff’s complaint when determining that an action is frivolous. This issue is
therefore inadequately briefed. See Kropp, 895 N.W.2d at 653.
Our deferential standard of review does not permit reversal under the present
circumstances. The district court did not make factual findings unsupported by the record,
misapply the law, or resolve a question contrary to logic and the facts on record. See
Woolsey, 975 N.W.2d at 506. We therefore conclude that the district court did not abuse
its discretion, and we defer to the district court’s ultimate determination that the action
underlying this appeal is frivolous.
Affirmed.