Background
Eric William Groebner served as a patrol officer with the Anoka Police Department from 2014 until his death in September 2022. On September 13, 2022, he worked a 12-hour shift during which he responded to eleven calls, including a domestic disturbance involving a reported child with a knife — a call to which he drove at up to 59 miles per hour through a residential neighborhood. The next morning, Groebner collapsed at home. The medical examiner determined that he died from a rupture of an ascending aortic aneurysm with cardiac tamponade — a “vascular rupture” within the meaning of Minn. Stat. § 299A.41, subd. 3(a).
His widow, Holly Groebner, applied for state line-of-duty death benefits under Minn. Stat. §§ 299A.41–.47 and submitted a medical expert report opining that the stressful nature of police work contributed to the development of Groebner’s aortic disease. The federal Public Safety Officers’ Benefits Office approved her federal claim, finding that Groebner died within 24 hours of engaging in “nonroutine stressful physical emergency response activity.” The Minnesota Commissioner of Public Safety denied the state claim, however, and an Administrative Law Judge granted summary disposition in the Commissioner’s favor, concluding that Groebner’s shift activity did not expose him to the hazard of being killed under the Kramer/Johnson standard.
The court of appeals reversed and remanded, finding a genuine issue of material fact as to whether the domestic disturbance call was “nonroutine,” but also held that the 2016 statutory amendments creating a presumption for heart-related deaths displaced the older Kramer/Johnson framework entirely for such deaths. Both parties petitioned the Minnesota Supreme Court — the Commissioner on the meaning of “nonroutine,” and Ms. Groebner on whether Kramer/Johnson survived the 2016 amendments.
The Court’s Holding
The court held that “nonroutine” as used in Minn. Stat. § 299A.41, subd. 3(a)(1)(i) is ambiguous because dictionary definitions support both the Commissioner’s reading (“special or extraordinary”) and Ms. Groebner’s reading (“not customary or part of regular procedure”). Resolving that ambiguity through legislative history, the court found that the Legislature enacted the 2016 amendments specifically to bring Minnesota law into conformity with the federal Hometown Heroes Act and to create a “one-stop shop” for benefit determinations. Because the state and federal statutes are substantially identical, the court construed “nonroutine” consistently with the federal implementing regulations at 28 C.F.R. § 32.13: an emergency response is presumptively “nonroutine” regardless of how the public safety agency characterizes it or how frequently such responses occur. The court also held that the phrase “nonroutine stressful or strenuous physical” grammatically modifies the entire series of listed activities in subdivision 3(a)(1)(i) — law enforcement, fire suppression, rescue, hazardous material response, emergency medical services, prison security, disaster relief, and other emergency response activity — not only “law enforcement.”
On a different ground than the court of appeals, the Supreme Court affirmed that a genuine issue of material fact exists as to whether Groebner engaged in nonroutine stressful or strenuous physical law enforcement or emergency response activity during his last shift, and remanded for further proceedings consistent with that standard.
The court reversed the court of appeals on the Kramer/Johnson question. The 2016 presumption for heart-related deaths did not extinguish the preexisting statutory framework. If an officer’s death does not satisfy the presumption criteria — or if the Commissioner rebuts the presumption with competent medical evidence — the officer’s estate may still present its own medical evidence to show that the death was “killed in the line of duty” under the standard articulated in Kramer v. State, Peace Officers Ben. Fund, 380 N.W.2d 497 (Minn. 1986), and Johnson v. City of Plainview, 431 N.W.2d 109 (Minn. 1988).
Key Takeaways
- An emergency response call qualifies as “nonroutine” under Minn. Stat. § 299A.41, subd. 3(a)(1)(i) as a matter of presumption; neither the agency’s label of the call as routine nor the frequency with which officers perform similar calls is dispositive.
- The modifier “nonroutine stressful or strenuous physical” applies to every category of activity listed in subdivision 3(a)(1)(i) — not just “law enforcement” — so all listed activities must satisfy that standard to trigger the presumption.
- The 2016 heart-attack presumption is an additional pathway to benefits, not a replacement for Kramer/Johnson; estates can still prove line-of-duty causation through medical evidence if the presumption fails or is rebutted.
- Minnesota courts will look to federal PSOB statute implementing regulations (28 C.F.R. § 32.13) and Bureau of Justice Assistance guidance as persuasive authority when construing the parallel state statute.
Why It Matters
This decision significantly broadens the path to line-of-duty death benefits for survivors of officers who die from heart attacks, strokes, or vascular ruptures in Minnesota. By anchoring “nonroutine” to the federal regulatory standard — one that explicitly forbids agencies from defeating claims simply by labeling calls as routine or pointing to their frequency — the court forecloses a major avenue that the Commissioner had used to deny benefits at the summary disposition stage. Officers who respond to domestic disturbances, traffic stops, or other calls that agencies routinely handle may still qualify for the presumption if the circumstances involved objectively stressful or strenuous physical engagement.
Equally important for practitioners is the court’s preservation of the Kramer/Johnson framework as a fallback. Survivors whose claims do not satisfy the statutory presumption — or whose presumption is rebutted by the Commissioner’s medical evidence — retain the ability to litigate line-of-duty causation through their own expert testimony. The ruling prevents the 2016 amendments from being read as inadvertently narrowing benefits for the very class of claimants the Legislature intended to help.