Eric William Groebner, a patrol officer with the Anoka Police Department in Minnesota, worked a 12-hour shift on September 13, 2022, responding to a mix of routine and emergency calls, including burglary assistance, traffic stops, and a domestic disturbance involving a child reportedly holding a knife. He returned home after his shift without reporting any medical issues and was found deceased the following day. The medical examiner determined that he died from a rupture of an ascending aortic aneurysm, classified as a vascular rupture.
Groebner’s widow applied for state line-of-duty death benefits under Minn. Stat. §§ 299A.41–.47. The Commissioner of Public Safety denied the claim, concluding that Groebner’s final shift did not involve “nonroutine stressful or strenuous physical” activity sufficient to trigger the statute’s presumption that certain heart-related deaths occur in the line of duty. An administrative law judge granted summary disposition in favor of the Commissioner, finding that Groebner’s activities during his final shift did not meet the statutory criteria as a matter of law. The court of appeals reversed, holding that there was a genuine factual dispute as to whether Groebner’s activity was “nonroutine,” and remanded for further proceedings. The Minnesota Supreme Court granted review.
The Court addressed two primary issues: what counts as “nonroutine stressful or strenuous physical” activity under the statute, and whether the statutory presumption replaces prior judicial definitions of a line-of-duty death. It first held that the term “nonroutine” is ambiguous and must be interpreted in context. Looking to similar federal law, the Court concluded that emergency responses are generally considered “nonroutine,” even if officers perform similar duties regularly or the agency considers them routine. The Court also clarified that the phrase “nonroutine stressful or strenuous physical” applies to all the listed categories of activity — such as law enforcement, rescue, or emergency response — meaning that any qualifying activity must meet that standard.
Applying that interpretation, the Court rejected the Commissioner’s argument that Groebner’s shift could be treated as routine as a matter of law. It emphasized that responding to emergency calls is not made routine simply because it happens often. Even common types of calls may involve uncertain, potentially dangerous, or highly stressful situations. Viewing the evidence in the light most favorable to Groebner’s estate, the Court found that his responses to emergency calls — including the domestic disturbance — could have involved circumstances presenting potential danger or heightened stress. On that basis, the Court held that there remained a genuine issue of material fact as to whether his work met the statutory standard, making summary disposition improper.
The Court next addressed whether the statutory presumption for deaths caused by heart attack, stroke, or vascular rupture replaces earlier case law defining “killed in the line of duty,” including Kramer v. State, Peace Officers Benefit Fund and Johnson v. City of Plainview. Those cases establish that a death may qualify if it results, at least in part, from duties that expose an officer to the hazards of the job. The Commissioner argued that the statutory presumption is the exclusive path to recovery in these types of cases. The Court rejected that argument.
Instead, the Court explained that the statute creates a burden-shifting framework, not a replacement rule. If the presumption applies and is not rebutted, the death is treated as occurring in the line of duty. But if the presumption does not apply, or is rebutted by medical evidence, the claimant may still attempt to prove that the death qualifies under the standards set out in Kramer and Johnson. The Court emphasized that the statute does not eliminate these alternative avenues of proof.
Because the record, viewed in the light most favorable to the claimant, supported the possibility that Groebner engaged in qualifying activity, the Court affirmed the court of appeals’ conclusion — on different reasoning — that summary disposition was improper. It further clarified that, if the statutory presumption ultimately does not apply or is rebutted, the claimant may still proceed under the existing case law.
The case was remanded for further proceedings consistent with the Court’s decision.
In the Matter of a Public Safety Officer Death Benefit for Eric William Groebner, No. A24-1410, 2026 WL 1579625 (Minn. June 3, 2026).