Lori Elaine Christensen v. State of Minnesota

This opinion is nonprecedential except as provided by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
A26-0310

Lori Elaine Christensen, petitioner,
Appellant,

vs.

State of Minnesota,
Respondent.

Filed October 12, 2026
Affirmed
Wheelock, Judge

Ramsey County District Court
File No. 62SU-CR-22-2353

Cathryn Middlebrook, Chief Appellate Public Defender, Kathryn J. Lockwood, Assistant
Public Defender, St. Paul, Minnesota (for appellant)

Keith Ellison, Attorney General, St. Paul, Minnesota; and

Caroline Bell Beckman, White Bear Township Prosecutor, Megan E. Oslund, Assistant
Township Prosecutor, Erickson, Bell, Beckman & Quinn, PA, Roseville, Minnesota (for
respondent)

Considered and decided by Wheelock, Presiding Judge; Frisch, Chief Judge; and
Harris, Judge.
NONPRECEDENTIAL OPINION
WHEELOCK, Judge
Appellant challenges the denial of her petition for postconviction relief, arguing that
there was insufficient evidence to support her conviction for disorderly conduct and that

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she did not commit disorderly conduct because her conduct was directed at a township
employee. We affirm.
FACTS
A jury found appellant Lori Elaine Christensen guilty of disorderly conduct in
violation of Minn. Stat. § 609.72, subd. 1(3) (2022). We set forth the following facts based
on the trial evidence.
On August 16, 2022, an employee of White Bear Township was mowing grass and
maintaining a tract of land owned by the township that is adjacent to Christensen’s
property. After the employee finished mowing, he saw Christensen standing in the street
and motioning for him to come over to her. Christensen had previously reported to the
township her issues with its maintenance of that tract of land. As he had been instructed,
the employee did not go over to or speak with Christensen and instead turned around and
proceeded to his work truck to load the mower into the trailer.
The employee testified that, as he arrived at his truck, Christensen drove up to his
location and placed her vehicle so that it was “sort of obstructing [his] ability to leave,”
“diagonally or crosswise in front of [his] vehicle.” While she was about ten feet away,
Christensen began filming the interaction on her phone and told the employee that she was
dissatisfied with his mowing and repeatedly stated that he had missed an area of grass. The
employee continued loading the mower into his truck; he “listened and listened” and then
finally told Christensen that, if she had an issue, she needed to speak to the township office.
The employee then got into his truck and “[d]id [his] best to get around her car, which was
a direct obstruction to get out of that situation.” The parties do not dispute that the video

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Christensen filmed does not show that Christensen’s vehicle blocked the employee’s
truck.1
During his testimony, the employee was asked what he thought “ Christensen was
going to do at that point,” and the employee responded, “I didn’t really know. I was
nervous about it . . . . I never had difficult interactions with anybody.” When asked how
he felt about being approached and “blocked . . . in,” he stated, “I was afraid. That’s all I
can say, I was afraid. I didn’t want a confrontation. That was not something I was
comfortable with. And it’s something I hadn’t experienced before.” The employee further
stated that Christensen’s “level of anger” was “noteworthy” because the lawn’s care
“seemed trivial.” After his interaction with Christensen, the employee returned to the
office and told his supervisor what occurred, but he was unaware of who subsequently
contacted police.
On cross-examination, the employee explained that Christensen initially pulled her
vehicle parallel to his so that her driver’s side window was near him. He stated that, after
he told Christensen to call the township, “she pulled her car around in front of [his] truck,
which is not shown in the video.”
Christensen testified that she placed her vehicle parallel to the employee’s truck and
asked if he was coming back to mow the strip that the township “had been ignoring.”

1 Although the video Christensen took on her phone of the interaction was admitted into
evidence at trial, it is not available to this court because it was purged from the record by
district court staff. The Office of the Clerk of the Appellate Courts sent the parties a letter
alerting them that the district court had purged the video and that it is not available to us
on appellate review. No party moved to supplement the record. We therefore proceed to
address this case based upon the record before us.

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Christensen stated that, after the employee told her to call the township, she was
“[f]rustrated,” so she drove beyond the trailer hitched to the employee’s truck to obtain the
trailer number. She asserted that, afterwards, she pulled away and drove home. She
testified that the only part of the employee’s testimony with which she disagreed was his
statement that she initially placed her vehicle diagonally in front of the employee’s truck.
She stated that she parked parallel to his truck and never went to the front side of his truck.
Christensen also agreed that she told the employee that she paid his wages, but denied
swearing at him, stating that she did swear but only when talking about another township
employee.
The jury found Christensen guilty, and the district court sentenced her to 90 days in
jail, 80 days of which was stayed for one year of supervised probation and ten days of
which was to be served on home detention.
Christensen filed a postconviction petition with the district court, arguing that the
evidence is insufficient to sustain her conviction and that the conviction violates her right
to free speech. The district court denied the petition on December 8, 2025.
Christensen appeals.
DECISION
A defendant may secure postconviction relief by petitioning the district court “to
vacate and set aside the judgment . . . or make other disposition as may be appropriate.”
Minn. Stat. § 590.01, subd. 1 (2024). We review a district court’s decision to summarily
deny a postconviction petition for abuse of discretion. Williams v. State, 5 N.W.3d 399,
405 (Minn. 2024). A district court abuses its discretion in denying a postconviction petition

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when it has “exercised its discretion in an arbitrary or capricious manner, based its ruling
on an erroneous view of the law, or made clearly erroneous factual findings.” Pearson v.
State, 891 N.W.2d 590, 596 (Minn. 2017) (quotation omitted).
I. The evidence is sufficient to support Christensen’s disorderly-conduct
conviction.

Christensen was convicted of disorderly conduct. The statute for that offense
prohibits a person “in a public or private place” from engaging in “offensive, obscene,
abusive, boisterous, or noisy conduct or in offensive, obscene, abusive language tending
reasonably to arouse alarm, anger, or resentment in others.” Minn. Stat. § 609.72,
subd. 1(3). To be criminally liable, the person must act “knowing, or having reasonable
grounds to know that it will, or will tend to, alarm, anger or disturb others or provoke an
assault or breach of the peace.” Id., subd. 1 (2022). Charges under this subdivision “must
be closely scrutinized” to avoid interfering with First Amendment rights. In re Welfare of
M.A.H., 572 N.W.2d 752, 757 (Minn. App. 1997) (quoting State v. Klimek, 398 N.W.2d
41, 42 (Minn. App. 1986)). “[A] defendant’s words are considered as a ‘package’ in
combination with conduct and physical movements, viewed in light of the surrounding
circumstances.” Id. (quoting Klimek, 398 N.W.2d at 43).
The parties do not argue that Christensen’s words alone can support a conviction.
2
The parties agree that Christensen’s words combined with her act of placing her vehicle to

2 The mere content of speech is considered disorderly conduct only if it consists of “fighting
words.” State v. Crawley, 819 N.W.2d 94, 105-06 (Minn. 2012). Fighting words are
generally words that, “as a matter of common knowledge,” are “inherently likely to
provoke” acts of violence by those persons to whom the statement is being addressed. State
v. Jorgenson, 946 N.W.2d 596, 604 (Minn. 2020) (emphasis omitted) (quotation omitted).

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block the employee’s truck from leaving the interaction are sufficient to sustain the
conviction. Christensen argues, however, that the state did not prove that she blocked the
employee’s truck because the evidence presented at trial, including Christensen’s
cell-phone video, does not show that she blocked the employee’s truck.
The district court denied the petition for postconviction relief because Christensen’s
“words[,] coupled with her conduct and physical movements,” supported the verdict. The
district court stated that the “jury could have reasonably concluded” that Christensen
“intentionally blocked [the employee]’s vehicle by parking at an angle in front of him as
he described” and that Christensen’s conduct caused the employee to be afraid.
When the challenged element is supported by direct evidence, “we must ascertain
whether, given the facts in the record and the legitimate inferences that can be drawn from
those facts, . . . the jury, acting with regard for the presumption of innocence and the State’s
burden of proof beyond a reasonable doubt, could reasonably conclude that the defendant
was guilty.” State v. Jones, 4 N.W.3d 495, 501 (Minn. 2024) (quotation omitted). “[W]e
view the evidence in the light most favorable to the verdict and assume that the factfinder
disbelieved any testimony conflicting with that verdict.” State v. King, 990 N.W.2d 406,
416 (Minn. 2023) (quotation omitted); accord State v. Loveless, 987 N.W.2d 224, 246
(Minn. 2023) (stating that appellate courts “assume that the jury believed the state’s
witnesses and disbelieved any evidence to the contrary” (quotation omitted)).

The state does not argue that Christensen’s statements to the employee constituted fighting
words.

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During the employee’s testimony, the state introduced the cell-phone video into
evidence and played it for the jury. On cross-examination, the employee agreed that
Christensen initially placed her vehicle parallel to his truck but also stated, “My
recollection is she pulled her car around in front of my truck, which is not shown in the
video.”
Credibility determinations are reserved for the jury, even when a witness’s
testimony contains inconsistencies or is uncorroborated. State v. Epps, 949 N.W.2d 474,
487 (Minn. App. 2020), aff’d, 964 N.W.2d 419 (Minn. 2021); see also State v. Pendleton,
706 N.W.2d 500, 511 -12 (Minn. 2005) (“Even where witness credibility has been
challenged, the jury may nonetheless believe the witness.”) . And we assume the jury
believed the state’s witness and disbelieved evidence to the contrary. Loveless,
987 N.W.2d at 246.
The disputed fact here is whether Christensen placed her vehicle in front of the
employee’s truck and blocked him in, preventing him from leaving. The parties presented
conflicting evidence; the employee testified that Christensen blocked his truck, Christensen
denied doing so, and the parties do not dispute that it was not shown in the video.3 Based
on its verdict, the jury credited the employee’s testimony over Christensen’s testimony.
The employee’s testimony is direct evidence that Christensen pulled in front of his truck.
Viewed in the light most favorable to the verdict, the evidence here is sufficient to support
Christensen’s conviction for disorderly conduct.

3 Because the parties do not dispute that the video does not show whether Christensen
blocked the employee’s truck, its relevance to the disputed fact is minimal.

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II. The district court did not err by denying Christensen’s postconviction petition
because the disorderly-conduct statute does not exclude conduct directed at a
township employee.

The disorderly-conduct statute prohibits a person from engaging in enumerated
conduct “tending reasonably to arouse alarm, anger, or resentment in others.” Minn. Stat.
§ 609.72, subd. 1(3) (emphasis added). Christensen argues that she cannot be convicted of
disorderly conduct because the conduct was directed at a township employee in the scope
of his employment and the statute’s use of the term “in others” cannot refer to a township
employee.
We apply the plain meaning of statutory language unless it is ambiguous. State v.
Plancarte, 20 N.W.3d 30, 37 (Minn. 2025). If the legislature has not defined a term, we
may apply a dictionary definition in the context of the statute to determine whether the
phrase is ambiguous. Fordyce v. State, 994 N.W.2d 893, 897 (Minn. 2023). The dictionary
defines “others” as a “different person or thing” or “[p]eople aside from oneself.” The
American Heritage Dictionary of the English Language 1249 (5th ed. 2011). The
dictionary definition does not include a limitation for township or other employees. See
id.
We conclude that the disorderly-conduct statute unambiguously prohibits certain
conduct directed at a person other than oneself, whether they are a township employee or
not. Minnesota caselaw supports this interpretation. See, e.g., State v. Zais, 805 N.W.2d
32, 40 (Minn. 2011) (stating that disorderly conduct “may be committed when there is only
one witness to the defendant’s conduct”); State v. Reynolds, 66 N.W.2d 886, 888 (Minn.
1954) (holding that it may be enough to constitute disorderly conduct under a predecessor

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statute “if the peace of only one member of the public or of one person is disturbed”); State
v. Janecek, 903 N.W.2d 426, 429 -30 (Minn. App. 2017) (stating that disorderly conduct
can occur when an individual “witness[es] the consequence or result of offensive conduct”;
they need not witness the conduct contemporaneously).
Christensen cites State v. Kaeo, 512 P.3d 154, 155 (Haw. 2021), a decision from
Hawai’i, to support her statutory-interpretation argument. We are not persuaded. We first
observe that decisions from other states are not binding authority. See Mahowald v. Minn.
Gas Co., 344 N.W.2d 856, 861 (Minn. 1984). Second, neither the statute nor the conduct
at issue in Kaeo is analogous to those here. In Kaeo, the Hawai’i Supreme Court interpreted
the language of that state’s disorderly-conduct statute, which includes the element of
“intending to cause (or recklessly creating the risk of causing) ‘physical inconvenience or
alarm by a member or members of the public.’” 512 P.3d at 155 (emphasis added) (quoting
Haw. Rev. Stat. § 711-1101(1) (2014)).
Kaeo was convicted of disorderly conduct after engaging in a protest blocking
trucks from transporting goods to be used for a telescope that was under construction and
inconveniencing “[a]bout twenty transport convoy workers.” Id. The Hawai’i Supreme
Court determined that “public,” as used in the statute, means the “community or the people
as a whole” and not members of an organization. Id. at 157. Because Kaeo’s conduct was
directed at the workers, who all were affiliated with the same organization, and there was
no evidence that Kaeo inconvenienced anyone other than the workers, his conduct did not
meet the statute’s requirements . Id. at 160; see State v. Lopez Ruiz,
No. CAAP-24-0000157, 2026 WL 1256977, at *1-2 (Haw. Ct. App. May 7, 2026)

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(concluding that individual who yelled and knocked on a neighbor’s walls and door at 1:00
a.m. did not violate Hawai’i’s disorderly-conduct statute because there was no evidence of
actual inconvenience to anyone other than the neighbor and the neighbor’s boyfriend), rev.
granted (Haw. Aug. 24, 2026).
Minnesota’s disorderly-conduct statute does not include the word “public” or any
other language that would exclude employees of an organization. Kaeo is not persuasive
here. Because there is no legal authority to support that Minnesota’s disorderly-conduct
statute excludes conduct directed at a township employee, we conclude that the district
court did not err in denying Christensen’s petition for postconviction relief.
Affirmed.